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Regulations on the processing and protection of personal data

Content

1. General provisions and scope of application.

2. Composition and content of personal data.

3. Purpose, limits and terms of processing personal data.

4. Location of personal data.

5. Conditions for disclosing personal data to third parties.

6. Protection of personal data.

7. Rights of the User (personal data subject).

8. Procedure for handling requests from personal data subjects (Users).

9. Amendments to the Regulations.

1. General provisions and scope of application.

1.1. These Regulations on the processing and protection of personal data (hereinafter referred to as the “Regulations”) have been developed by the Psychotherapy Center “AlterEgo” (EDRPOU code: 3135515889, address: Lviv, Stryyska Street, 45a, hereinafter referred to as the “Service Representative” and/or “Data Owner”) in accordance with the current legislation of Ukraine, including, but not limited to, the Law of Ukraine “On Personal Data Protection” dated June 1, 2010 No. 2297-VI, and establish the procedure for receiving, collecting, accumulating, storing, processing, using, ensuring the protection and disclosure of personal data (hereinafter referred to as the “Data” and/or “Personal Data”) using the website: alter-ego.net.ua (hereinafter referred to as the “Site”) and/or related services and tools.

1.2. By registering on the website alter-ego.net.ua or attempting to place an order without prior registration, the User provides permission and unambiguous consent to the processing of his personal data on the terms and in the manner set out below, and also confirms familiarization with these Regulations, its acceptance and agreement with its content.

1.3. Under “Psychotherapy Center “AlterEgo”” in these Regulations there is a Website (alter-ego.net.ua).

1.4. The owner of the Users' personal data is the Psychotherapy Center “AlterEgo” (EDRPOU code: 3135515889, address: Lviv, Stryyska Street, 45a).

1.5. In these Regulations, all terms are used in the meaning defined in the Law of Ukraine "On Personal Data Protection" dated June 1, 2010 No. 2297-VI.

1.6. The Site may contain links to other websites (for informational purposes only). When following a link to other websites, these Terms of Use will not apply to such sites. In this regard, the Service Representative recommends that you familiarize yourself with the privacy and personal data policies of each site before
transmit personal data by which you can be identified.

1.7. This Regulation is mandatory for application by the responsible person and employees of the online platform who directly process and/or have access to personal data in connection with the performance of their official duties.

2. Composition and content of personal data.

2.1. Data means any information that directly or indirectly relates to a specific User. This may include: name, surname, patronymic (if any), telephone number, email address, date of birth, presence of children, gender, hobbies, presence of pets, presence of a car and its VIN number, language of communication, address of residence/stay/delivery, information about the User's actions while using the Online Platform, IP address, data about devices used by the User (device type, browser type, device operating system), message history (information contained in correspondence between the User and the administration of the Service Representative, history of reviews or comments, other information through which communication is carried out, and which, at the User's request, is provided by him in the registration form and/or when filling out his own profile, when taking a survey (by filling out a questionnaire or in another way), or information obtained during oral communication between the User and the Site administration, information provided when making a payment for services. In particular: information regarding the User's passport data, identification code, etc.).
This list of personal data is not permanent and mandatory for all Users, but depends on the needs and wishes of the User himself and on the operations that he/she performs on the online platform. Data also refers to other information received by the Service Representative on a legal basis from third parties and/or available from the User's profiles on social networks - in the case of registration on the online platform using social network authentication services. In this case, the User gives his/her consent to the processing of information available from the relevant accounts (profiles) on social networks.

2.2. Users are responsible for all information posted by them in public accounts. The User must be aware of all risks associated with the fact that he publishes his address or information about his exact location. If the User decides to log in to the Online Platform using the authentication service of a third-party operator, for example, Facebook information, the Service Representative may receive additional profile, or other information, access to which is provided by such third party.

3. Purpose, limits and terms of processing personal data.

3.1. The purpose of processing personal data is:

  • ensuring the implementation of civil legal relations, tax relations, the implementation of the functions, powers and duties assigned to the Service Representative in accordance with the current legislation of Ukraine;
  • identification of the client as a User of the online platform, for communication with the User, including for the provision of services, payment processing, sending, conducting settlement transactions, providing reporting, maintaining accounting and management records, creating and implementing bonus programs, loyalty programs, sending newsletters by mail, e-mail, by phone number, including for the purpose of sending commercial offers, notifications about promotions and news of the online platform, and/or for providing Users of the online platform with financial services (provided by third parties and/or partners of the Company), in order to improve the quality of goods/provision of services, forming ratings of goods and offers of the online platform, analyzing User activity, performing keyword searches, managing traffic in the online platform, analyzing and predicting User preferences and interests to form the most relevant and profitable personal offers or promotional offers; conducting research and analytical activities, sending information and marketing newsletters (news, company promotions, information about promotions, promotional codes and discounts, personal recommendations, personal discounts and offers), which contain information about goods and/or services, advertising and commercial offers regarding such goods and/or services, etc.;
  • in order to fulfill other obligations imposed by law on the Owner of personal data, to protect the legitimate interests of the Owner of personal data or a third party to whom the personal data is transferred.

3.3. The Service Provider does not process data relating to racial or ethnic origin, political opinions, religious or other beliefs, membership in public organizations. Information characterizing the physiological characteristics of Users, on the basis of which their identity can be established, is also not processed.

3.4. The terms of processing and storage of Data are determined based on the purposes of processing the Data, as well as based on the terms specified in the agreements concluded with Users in accordance with the requirements of the current legislation of Ukraine. Personal data are processed and stored for as long as necessary to achieve the purposes for which they were collected, including to fulfill any legal, accounting or reporting requirements or until the data is deleted by the User or at the User's request.

4. Location of personal data.

4.1. Personal data of Users of the online platform are processed and protected on the Company's secure servers.

5. Conditions for disclosing personal data to third parties.

5.1. The Service Representative may exchange Data with affiliates of the Company (companies operating under common ownership), who may process and use the Data for the purposes specified in these Regulations.

5.2. Data is disclosed when the User orders goods/services on the Online Platform to sellers of such goods and services to the extent necessary to identify the User, fulfill and process the User's order (including for the purpose of properly making payments for goods/services, ensuring the User receives financial services, etc.).

5.3. The Service Representative may engage third-party suppliers of goods/services to fulfill the Order, in such cases, such third-party suppliers of goods/services are not authorized to use personal data obtained through the Online Platform, other than to fulfill the Order.

5.4. The Service Provider may transfer certain depersonalized information, as well as authorize the collection of such depersonalized information directly on the website using appropriate technologies (data that does not allow for the identification of Users individually) to third-party service providers, trusted partners or authorized researchers for the purpose of conducting market research, improving the effectiveness of advertising offers and campaigns (by offering more relevant offers of the online platform), analytical activities, better understanding what advertising, goods and/or services may be of interest to Users, improving the overall quality and effectiveness of goods/services on the Online Platform, etc.

5.5. The Service Representative may also exchange Data with suppliers of goods/services during the conduct of contests, promotions and promotions on the Online Platform in order to properly ensure the conduct of such contests, promotions and promotions. In such case, the Data is used and may be transferred to third parties for the purposes and for the purpose of
conducting such contests, promotions and promotions, determining the winner. In the event of a win/victory, if contests, promotions and promotions are conducted by suppliers of goods/services, such suppliers of goods/services may independently contact Users regarding the conduct of contests, promotions and promotions, determining winners, processing the prize, etc.

5.6. The Service Representative processes Data on a lawful and fair basis: Data is not disclosed to third parties and is not distributed without the consent of the User, except in cases provided for by the current legislation of Ukraine and only in the interests of national security, economic well-being and human rights, in particular, but not exclusively:

  • upon reasonable requests from government authorities that have the right to request and receive such Data;
  • for the purposes of combating fraud and abuse on the Online Platform.

5.7. In cases of transfer of personal data provided for in Section 5 of these Regulations, informing the User about the transfer of his personal data remains at the discretion of the Company.

6. Protection of personal data.

6.1. The owner of personal data is equipped with system and software and hardware and communication means that prevent loss, theft, unauthorized destruction, distortion, forgery, copying of information and meet the requirements of international and national standards.

6.2. Employees/authorized persons who directly process and/or have access to personal data in connection with the performance of their official (labor) duties are obliged to comply with the requirements of the legislation of Ukraine in the field of personal data protection and internal documents regarding the processing and protection of personal data.

6.3. Employees/authorized persons who have access to personal data, including those who process them, are obliged to prevent the disclosure in any way of personal data that has been entrusted to them or that has become known in connection with the performance of professional, official or labor duties. Such an obligation is valid after the termination of their activities related to personal data, except for cases established by law.

6.4. Personal data shall not be stored for longer than is necessary for the purpose for which such data is stored, but in any case not longer than the data storage period specified in these Regulations with the consent of the User.

6.5. This Regulation sets out internal policies and procedures for the collection, processing, use, and disclosure of personal information or personal data when using the alter-ego.net.ua website. The Data Owner has developed and implemented internal rules for working with personal data, including the levels of access of internal employees of the Company to User data, and a secure procedure for exchanging such data within the Company. The Service Representative regularly audits its security systems in order to identify opportunities to improve the secure storage and use of User data. The Service Representative also complies with the requirements of the Standard Procedure for Processing Personal Data, approved by the Order of the Verkhovna Rada of Ukraine dated 08.01.2014 No. 1/02-14 (see https://zakon.rada.gov.ua/laws/show/v1_02715-14#Text) to the extent that it specifically applies to personal data.

7. Rights of the User (personal data subject).

7.1. The subject of personal data (User) has the right:

  • to know about the location of personal data containing his personal data, its purpose and name, location and/or place of residence (stay) of the owner or manager or to give the appropriate instruction to obtain this information to persons authorized by him, except for cases established
    by law;
  • receive information about the conditions for providing access to personal data, in particular information about third parties to whom his personal data is transferred;
  • to access your personal data;
  • receive no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, a response on whether his personal data is stored, as well as receive the content of his personal data that is stored;
  • to submit a reasoned request with an objection to the processing of their personal data by state authorities and local self-government bodies when exercising their powers provided for by law;
  • to protect their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision of such data, as well as to protect against the provision of information that is unreliable or defamatory of the honor, dignity and business reputation of an individual;
  • to address issues of protecting their rights regarding personal data to state authorities and local self-government bodies whose powers include the protection of personal data;
  • apply legal remedies in case of violation of personal data protection legislation.

8. Procedure for handling requests from the personal data subject (User).

8.1. The subject of personal data (User) has the right to receive any information about himself from any subject of relations related to personal data, without specifying the purpose of the request, except for cases established by law.

8.2. Access by the subject of personal data (User) to data about himself/herself is free of charge.

8.3. The personal data subject (User) submits a request for access (hereinafter referred to as the request) to the personal data controller. The request shall specify:

  • surname, first name and patronymic, place of residence (place of stay) and details of the document certifying the identity of the personal data subject (User);
  • other information that allows identifying the person of the personal data subject (User);
  • information about the personal data in respect of which the request is made, or information about the controller or administrator;
  • a list of personal data requested.

8.4. The period for examining a request for its satisfaction may not exceed ten working days from the date of its receipt.

8.5. During this period, the Owner of personal data shall inform the subject of personal data (User) that the request will be satisfied or the relevant personal data shall not be provided, indicating the grounds specified in the relevant regulatory legal act.

8.6. The request shall be satisfied within thirty calendar days from the date of its receipt, unless otherwise provided by law.

9. Amendments to the Regulations

9.1. The Service Representative may from time to time unilaterally update these Regulations without notifying the User of such changes. The new version of the Regulations shall enter into force from the moment of its posting on the Online Platform, unless otherwise provided by the new version of the Regulations. The current version of the Regulations is always available on the page at: https://alter-ego.net.ua/….

9.2. If any changes have been made to the Regulations with which the User does not agree, he is obliged to stop using the online platform. The fact of continuing to use the online platform is confirmation of the User's consent and acceptance of the relevant version of the Regulations.