PRIVACY AND DATA PROTECTION POLICY

This Privacy and data protection policy (hereinafter – the “Policy”) defines how the Website Administration gathers, collects and processes the User`s personal data obtained by virtue of the latter`s using the Website available via the link: https://sumsum.com.ua (hereinafter – the “Website”), the purpose and procedure of such a use, the rights of personal data owners, contact information for receiving the access to the personal data, changing, supplementing or deleting the User’s personal data together with other terms dealing with personal data protection.

Please note that:

• • The Website is limited by the minimal scope of data required for the due performance of the agreements concluded via the Website and/or with the use of other means of liaison acceptable for both Parties and for the Users' orders processing;
• • The Website Administration doesn’t verify the validity of the personal data provided by the User. The Website Administration assumes that the User provides reliable data and keeps such data up to date. The User bears all responsibility, as well as the risk of providing inaccurate, incomplete, wrong or irrelevant information.
• • This Policy applies exclusively to the Website. The Website Administration doesn’t monitor and has no responsibility for the third parties’ websites which may be available by the links referred to on the Website.
• • Use of the Website by the User implies the User`s consent with this Policy and the processing of his personal data.
• • In case the User’s disagrees with this Policy, he / she shall immediately stop the use of the Website.
• • All offers and questions regarding this Policy shall be notified to the Seller by phone or by any other means of liaison according to details specified on the Website.

1. Definitions of terms

1.1. The terms in this Policy shall have the meaning hereunder assigned to them:

• Website Administration
  the Seller’s employees authorized to manage the Website, which organize and carry out the personal data processing, define the purposes of the personal data processing, the content of personal data, actions and transactions with personal data.
• Accept
  specific and expressed User’s consent with the use and processing of his/her personal data, provided by him / her when ordering the Goods via the Website or acting in any another way which may constitute the approval.
• Confidentiality of personal data
  requirement not to allow the personal data disclosure without the User’s consent or other legal grounds, which is mandatory for the Website Administration or other person who has access to the personal data.
• User (Buyer)
  an individual, who has the access to the Website and uses the Website through the Internet (personal data subject).
• Personal data processing
  any act (transaction) or set of acts (transactions) with the personal data, whether carried out with the use of automation equipment or not, including collecting, recording, systematization, accumulating, storage, clarifying (updating, changing), extraction, using, sharing (dissemination, providing, access), depersonalizing, blocking, deleting, destruction of the personal data.
• The User’s account
  information about the User, provided by him / her at the time of filling the application form to make the order via the Website or using other means of liaison, exactly identifying the User during his use of the Website.
• Personal data
  any information directly or indirectly related to the individual, who has been identified or may be identified (personal data subject).
• Cookies
  a small fragment of data sent to the webserver and maintained on the User’s computer; this fragment is sent by the web client or web browser to the webserver in HTTP-request each time when the User is trying to open the page of the respective Website.
• IP-address
  an unique network point address in computer network, built under the IP protocol.

2. The purpose of the personal data collecting and processing

2.1. The User’s personal data shall be used for the following purposes:

• 2.1.1. the User’s registration and login in the Website, provision to the User the access to the personalized resources of the Website;
• 2.1.2. identification of the User, registered on the Website for the Goods’ ordering purposes;
• 2.1.3. processing of the User’s requests and applications;
• 2.1.4. payment for the Goods, processing and receiving of respective payments, invoicing, the accompanying documents issuance and delivery of the Goods ordered by the User;
• 2.1.5. connecting with the User for receiving feedback, including the messages, claims regarding the use of the Website; notifying the User about the order and delivery statuses;
• 2.1.6. providing the User with an effective client and technical support in case of any problems related to the use of the Website.
• 2.1.7. providing the User (subject to his prior consent) with updates, special offers, pricelists, newsletters and other information with the prior consent of the User.
• 2.1.8. marketing and advertising purposes.

3. Legal grounds for the personal data collecting and processing

3.1. The personal data shall be collected and processed according to the the Laws of Ukraine “On personal data protection”, “On electronic commerce”, “On information” and other regulatory legal acts.

3.2. The personal data shall be processed solely on the basis of The User’s Accept.

3.3. By clicking the “I accept” button, the User voluntarily consents to the processing of his/her personal data. In the absence of the User`s consent to personal data processing, the User is not permitted to make the orders via the Website or using any other means of liaison with the Website Administration.

4. The scope the personal data the Website Administration collects and processes

4.1. Information provided by the User

4.1.1. For the purposes of this Policy, the Website Administration may collect and process the data provided personally by the User when filling application forms on the Website/ communicating with the Website Administration. In such a case the Personal Data which may be processed includes the following information:

• 1) the User’s full name;
• 2) The User’s phone number;
• 3) e-mail;
• 4) Goods delivery address
• 5) other information, provided by the User on his/her own, which is useful and expedient in his/her opinion.

4.2. Automatically collected information

4.2.1. Certain information on the User’s device, which is used to log in, and the information on the interaction process between the User and the Website. The information may be collected automatically for the marketing and analytical purposes. Such information shall be properly stored shall not be disclosed, except for the cases specified in clauses 7.1-7.3 hereof, and may include the following:

• 1) ІР-address (statistic on the User’s IP-addresses shall be provided for the purposes of controlling, revealing and solving technical problems);
• 2) the Internet-browser type;
• 3) the information on the device, which is used to visit the Website;
• 4) visited Website pages;
• 5) сookies.

4.2.2. The above information may be also used to reveal and solve the technical problems, as well as to control the validity of the financial transactions.

5. The ways of personal data is collected and processed

5.1. The User`s personal data shall be processed using any lawful means, including processing in personal data systems whether carried out with the use of automation equipment or not.

5.2. For the purposes of this Policy, the Website Administration shall take all measures required to prevent damages or any other negative consequences caused by loss or disclosure of the User`s personal data, considering the risk level triggered by such disclosure or loss together with the nature of the processed data.

5.3. The Website Administration shall take together with the User all organizational and technical steps required to protect the Users Personal Data from unlawful or accidental access, destruction, misuse, copy, dissemination and from other unlawful acts of third parties. The Users Personal Data shall be stored on the secure servers and shall not be publicly available. The Website Administration can not guarantee either the security of our databases or that information provided by you will not be intercepted by third parties.

6. Personal Data retention

6.1. The Personal Data shall be retained for a period indispensable for its processing.

6.2. The User`s Personal Data shall be automatically deleted as soon as the personal data subject ceases to be a User of the Website by deleting its account on the Website. The User`s account may also be deleted by his / her request and in case of withdrawing his consent with the personal data processing, objecting to the personal data processing, or requiring its deletion.

7. Disclosure of personal data to third parties

7.1. The Website Administration does not sell, transfer, trade or otherwise disclose the User`s personal information to third parties without his prior consent thereto. However, the User consents that the Website Administration may disclose personal data to the third persons, namely to its employees, exclusively for the purposes of Website order completion, including Goods delivery.

7.2. The Website Administration reserves the right to share the User`s personal data to the public authorities if such disclosure is envisaged by the Ukrainian legislation;

7.3. In case of Personal Data loss or disclosure the Website Administration shall immediately inform the User thereon.

8. Rights of personal data subject

8.1. By using the Website, the User expressly consents to the collection and processing of its personal data subject to the conditions prescribed in this Policy and the Law of Ukraine “On personal data protection”, The User, being the personal data subject, is endowed with the following rights:

• 1) to receive information on the granting the access to the personal data, namely, information on the third persons to which the personal data is transferred;
• 2) to access his / her personal data;
• 3) to object to the processing of personal data by submitting a justified written claim to the holder of the personal data;
• 4) to submit a justified written claim with a request to supplement or delete his / her personal data by any holder of the personal data, provided, that such data is unreliable or processed using unlawful means;
• 5) to protect his / her personal data from unlawful processing or accidental loss, destruction, damage due to intentional conciliation, non-provision or late provision or from provision of data which is unreliable or undermines his / her dignity or business reputation;
• 6) to lodge a complaint with the Ukrainian Parliamentary Commissioner for Human Rights;
• 7) to invoke means of legal protection in case the data protection laws are violated;
• 8) to withdraw his consent to the personal data processing.

8.2. The above list of the personal data subject in not exhaustive. One can find more detailed list in the Law of Ukraine “On personal data protection”.

9. Dispute resolution

9.1. All disputes arising in the course of this Policy application, shall be resolved through negotiations and pre-trial proceedings, namely, by means of submitting a written claim to the Website Administration (written proposal to voluntary dispute settlement). The Website Administration undertakes, during 15 days following the receipt of the claim, to notify in writing the User on the results of claim consideration.

9.2. In case the dispute can not be resolved during the pre-trial proceeding, such dispute shall be referred to the Ukrainian courts and settled under respective Ukrainian legislation.

10. Changes to the Privacy Policy

10.1. The Website Administration shall be entitled to amend and supplement periodically this Privacy Policy without giving to the User any prior notification thereon.

10.2. The updated version of the Privacy Policy becomes operative from the moment of its publication on the Website, except as provided in clause 10.3. of this Policy.

10.3. In case of any material changes to the provisions of this Privacy Policy, the notification thereon together with the respective effective date of the modified version shall be posted on the Website. If during the reasonable period the User does not raise any written objection to the changes, the amended version shall considered as have been accepted by the User.