Date: 01.11.2022
Last Updated: 01.11.2022

Data Protection Policy "YOUCONTROL" LTD

Introduction

This Data Protection Policy ("Data Protection Policy") describes and summarizes the policies and procedures of "YOUCONTROL" LTD with respect to the processing of personal data ("Personal Data") provided or acquired through use of our website https://youcontrol.market) and other products (hereinafter "our products" or "products"). Please note that the use of our products does not require you to provide any Personal Data.

For the purpose of the General Data Protection Regulation ("GDPR") Data Protection Bill and the California Consumer Privacy Act ("CCPA") (collectively, "Data Protection Laws"), the data controller in relation to our products visitors and users is "YOUCONTROL" LTD (hereinafter "YouControl", "we", "our" or "us").

The protection of your Personal Data is of supreme importance to YouControl. We are committed to maintaining the security, confidentiality and integrity of the Personal Data in our custody or control, and protecting such data in accordance with the applicable legislation. YouControl regularly re-evaluates its privacy and security practices and adapts them as necessary to deal with new regulatory requirements, changes in legislation, its services and/or security standards.

We do not store credit card details nor do we share customer details with any third parties.

Information We Collect About You

Whenever we collect Personal Data from you, we let you know and you will be able to access the following precise information:

• • Personal Data we have collected from you;
• • the basis on which we are holding it (e.g. because you gave us consent, processing provided for by law etc.);
• • what we will do with it;
• • how long we will hold it for;
• • who it might be shared with;
• • your rights in relation to your Personal Data;
• • information on how you can access and manage Personal Data.

We have provided further detail below about the specific types of Personal Data we collect and our reasons for doing so.

We collect Personal Data about:

• • our website visitors;
• • our website registered users - agents (incl. personnel) of our clients who use our services.

When you visit our website we collect standard internet log information and details of visitor behavior patterns, such as:

• • date and time of your visit;
• • type and version of the browser you use;
• • operating system;
• • your IP address
• • the full URL clickstream to, through and from our website.

YouControl typically collects the following categories of our website registered user’s Personal Data:

• • biographical data such as first and last name;
• • contact data such as email address;
• • any other Personal Data that you may decide to share with us, for example, such as communication and support data that you share when you contact us.

Information Collected Automatically. Cookies Policy

In order to enable certain functionalities of our website and to help us analyze user behavior on the website in order to improve the customer experience, we may use cookies, web beacons and similar technologies on our website. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive, mobile phone or other device. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not. However, some of the services and features offered through our website may not function properly if your cookies are disabled. For more information, please read our Cookies Policy.

Use of Registered User Customer Service Area

When accessing the customer service area on our website which is reserved for registered users, you have to register using your unique user name and password. This information will be used to verify that you are an authorized user and not for any other purposes. In addition, we will record information about the services you have accessed through the registered user area for accounting purposes, to comply with our statutory obligations under applicable Data Protection Laws (e.g. to document your legitimate interest for accessing data), for our internal statistical and analytical purposes.

What Do We Do With the Information We Collect About You

We only collect the data that is necessary to:

• • provide you with the information, products and services that you request, comply with our contractual obligations or enable us to enter into a contract with you;
• • provide you with information about other goods and services we offer that are similar to those you have already purchased or enquired about; we have a legitimate interest to use your data for this purpose unless you have told us not to provide such information to you;
• • provide you with information about goods or services we feel may interest you on the basis of the consent you have granted;
• • personalise your experience on our website and ensure that our website is displayed in the most effective manner for you and your device.

Please be aware that data transfer via the internet (e.g. when communicating via email) is subject to security risks. Therefore, complete protection against third-party access to transferred data cannot be ensured.

How We Protect Your Information

We keep your Personal Data secure:

• • by implementing and maintaining commercially reasonable measures to protect against unauthorized access to and unlawful interception or processing of Personal Data we process;
• • by following internal policies of best practice and training for staff;
• • by using SSL technology when Personal Data is submitted to us online.

Guidelines for Children

YouControl products are intended for a general audience, and are not directed at children under eighteen (18) years of age. If we find out about the processing of Personal Data of persons whose age has not reached the required legal minimum under the applicable laws, we will remove the data to the extent required by applicable laws without undue delay.

Newsletter and Business Updates

YouControl offers you the opportunity to receive business updates we provide and our occassional newsletters (collectively, "Newsletters"). To provide this information, we require a valid email address. No data is transferred to third parties, nor is any of this information matched to any information that other components of our website may contain. You may cancel your subscription to the Newsletters at any time. You will find additional details in the email confirming your subscription as well as in each Newsletters.

We use third party software and services for our email communications and we track user activity to ensure we are sending relevant content and providing a positive user experience.

Changes and Amendments to our Data Protection Policy

YouControl may change and amend this Data Protection Policy from time to time. Changes will be communicated through updates on our website. We recommend that you regularly access our website to ensure that you agree with any changes or amendments.

Information Transferred Internationally

YouControl is headquartered in Ukraine. If you are located outside Ukraine, your information is collected in your country and then transferred to Ukraine — or to another country in which we (or our affiliates, or service providers) operate.

What Is Our Legal Basis for Processing

Our legal basis for processing the Personal Data will depend on the purposes of the processing. YouControl will collect and process Personal Data based on the following legal bases:

• • processing is necessary for the performance of a contract to which the you are a party;
• • you gave us consent (e.g. to send you newsletters via email);
• • processing is necessary for compliance with a legal obligation to which YouControl is subject;
• • processing is necessary for the purposes of our legitimate interests such as marketing, troubleshooting and fixing errors on our website or improving our products.

If there is another legal basis for YouControl to collect and process Personal Data, YouControl will provide the required notification to you at or before the time the Personal Data is collected.

Your Privacy Rights

If YouControl processes your Personal Data, you may have the following privacy rights:

• • the right to be informed about the collection and use of your Personal Data;
• • the right of access to your Personal Data and any supplementary information;
• • the right to have any errors in your Personal Data rectified;
• • the right to have your Personal Data erased;
• • the right to block or suppress the processing of your Personal Data;
• • the right to move, copy or transfer your Personal Data from one IT environment to another;
• • the right to move, copy or transfer your Personal Data from one IT environment to another;
• • the right to object to our processing of your Personal Data in certain circumstances.

We give you the option to exercise your privacy rights via:

• • the settings of your account;
• • by our e-mail: [email protected]

We retain Personal Data for the duration of your relationship with us and two years thereafter. You have the right to submit a complaint to the data protection authority in the state of your habitual residence, place or work or the alleged violation of your rights under applicable legislation, including Data Protection Laws.

Your Right to Get Your Data Deleted

You can ask us to delete data that we hold about you in following cases:

• • your Personal Data is no longer necessary for the purpose which we originally collected or processed it for;
• • we are relying on consent as our lawful basis for holding the data, and you withdraw such consent;
• • there is no overriding legitimate interest to continue processing your Personal Data;
• • we are processing the Personal Data for direct marketing purposes and you object to that processing;
• • we have processed your Personal Data unlawfully;
• • we have to erase your data to comply with a legal obligation or we have processed the Personal Data to offer information society services to a child.

We can refuse to comply with a request wholly or partly if it is manifestly unfounded or excessive.To exercise your right to object you should inform us directly by our contacts (see below) or via the settings of your account (if you have one) that you don’t want us to process your data. You need to explain why you believe we should stop using your data.

Third Party Websites

The Services may include links to, or otherwise direct your attention towards, websites operated by third parties and not by YouControl. Such links are provided solely for your convenience and informational purposes. The inclusion of any link does not imply an association, support, endorsement, consent, examination, or approval by YouControl of such third party and third party website (including without limitation any content on such website).

Contact Address of the Controller of Your Personal Data

If you have any comments or questions regarding this Data Protection Policy or our use of your Personal Data, or would like to make a request, please contact us at:

"YOUCONTROL" LTD

Sverstyuk Eugene street, 11, office 515

Kyiv 02002

Ukraine

e-mail: [email protected]