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Privacy Policy

This Privacy Policy governs the relationship between Sole Trader S.M. Rushanskyi (hereinafter referred to as Smart Way) and any individual, self-employed person, entrepreneur, or legal entity (hereinafter referred to as the Client) regarding the processing of personal data (information) when using the service provided to the Client in accordance with the Terms of Access and Use of the Service. The Privacy Policy applies to all data and information received from the Client/Administrator/User during the use of the service. If any terms specified in this Privacy Policy are not accepted by the person intending to use the Service, such person is not entitled to use the Service.

1. General provisions

1.1. This Privacy Policy has been developed on the basis of the current legislation of Ukraine, including the Law of Ukraine "On Personal Data Protection".

1.2. The Privacy Policy is valid in accordance with the Terms of Access and Use of the Smart Way Service (the "License Agreement", the "License Agreement").

1.3. Familiarization and agreement with this Privacy Policy is mandatory to obtain the right to use the Smart Way service.

1.4. By registering on the smartway.pro website, the Client confirms that he/she has read all the documents mentioned above and this Privacy Policy. The consent of the personal data subject (Client) is a voluntary expression of will to grant permission to process personal data in accordance with the stated purpose of their processing, provided during registration in the system by marking the permission to process personal data in accordance with the stated purpose of their processing.

1.5. Processing of personal data means any action or set of actions, such as collection, registration, accumulation, storage, adaptation, modification, updating, use and dissemination (distribution, sale, transfer), depersonalization, destruction of personal data, including with the use of information (automated) systems.

1.6. When registering the Client/Administrator/User on the smartway.pro website, their account (profile) is automatically created, which includes a number of personal data. The Client/Administrator/User assumes full responsibility for the fact that the entered data is accurate, complete and up-to-date.

1.7. The Client independently chooses a password during registration, Smart Way is not responsible for its reliability and for the consequences of the Client's transfer of the password to third parties (Administrator/Users). Smart Way has the right to prohibit the use of certain logins, may set requirements (length, valid characters) for the formation of a password, encrypt passwords and use password management programs.

1.8. If Smart Way has reason to believe that the information provided is incomplete or false, Smart Way has the right, at its sole discretion, to block or delete the Client/Administrator/User account, as well as to prohibit the Client/Administrator/User from using the Service in whole or in part.

1.9. The Client is solely responsible for the distribution of data for access to the service (identifiers, passwords, etc.), for entering personal data of other persons (Administrator/Users), for the content of the content, including for the compliance of the content with the norms of the current legislation.

2. Information that is processed (collected). Purpose.

2.1. The information provided by Smart Way may include:

  • data, including data of third parties (Administrator/Users): name, date of birth, gender, postal address, e-mail, telephone number, information about bank accounts (card accounts), field of practice (activity) and/or photo, Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referring pages, interests, dates and times of login/logout, operating system;
  • information that constitutes the scope of the Client's labor relations, in particular, the Client's personnel records;
  • downloaded content;
  • information received about the Client/Administrator/User from other official sources, including social networks, and via messengers configured to work with the Service;

2.2. The Client guarantees that he/she has received all necessary permissions and consents to post personal information about third parties (Administrator/Users), and also guarantees the full and unconditional consent of these persons to all provisions of this Privacy Policy.

2.3. The Smart Way service informs that it uses cookies to personalize content, marketing, analytics, performance, provide security features and their launch, as well as the ability to access secure areas of the service.

2.4. Personal data may be processed for the following purposes:

  • proper provision of services for the administration and optimization of a set of recruitment and HR processes, maintenance of personnel records;
  • improvement of the service, including modernization in accordance with the Client's needs;
  • marketing purposes, namely informing the Client about new products of the Service;
  • communication with representatives of the service, including acceptance of proposals from the Client/Administrator/Users;
  • settlement of conflict situations;
  • ensuring the exercise of the rights of the Client/Administrator/Service Users.

2.5. Smart Way does not control the accuracy and relevance of the information provided, but has the right to request confirmation of its accuracy at any time.

2.6. Smart Way may provide the ability to integrate the Service with third-party products. Smart Way has the right to post links to third-party websites/services. In this case, Smart Way is not responsible for the collection, storage and processing of personal information by third-party software, i.e. this Privacy Policy does not apply to such cases.

2.7. Smart Way informs that the data provided by the Client/Administrator/User or collected by the Service about the Client/Administrator/Users will be copied and stored on servers located in Western Europe. Such backup and copying will ensure and facilitate the recovery of lost or damaged content.

2.8. Smart Way has the right to publish/post personal reviews of the Client/Administrator/User about the service on its website. If the Client/Administrator/User wishes to delete his/her review, he/she should send a corresponding letter to support@smartway.pro.

3. Cases of disclosure of personal information.

3.1. Personal data may be transferred for the performance of an agreement to which the Client may be a party or a beneficiary or guarantor, subject to the prior consent of the Client.

3.2. Personal data may be used to protect the rights and legitimate interests of the Service or third parties in cases where the User violates the copyright and other intellectual property rights of Smart Way and/or the relevant License Agreement. In this case, information may be transferred to regulatory/law enforcement authorities and the court.

3.3 Personal information may be transferred for connection and/or registration of third-party software products in the name of the Client, subject to prior consent of the Client.

4. Rights of the Client/Administrator/Users.

4.1 The Client/Administrator/Users have the right to:

  • to protect their personal data within the framework of this Privacy Policy and the current legislation;
  • edit your account (profile) by making changes and additions;
  • in the event of termination of use of the Service, demand the deletion of all account data and content;
  • download content related to the Client's activities and unload content at any time convenient for them. In the event of termination of the contractual relationship, the Client has 14 calendar days to upload the content, in case of delay in this period, the Service has the full right to independently delete the Client's content without consent and warning of such actions;
  • leave feedback on the work of Smart Way;
  • request Smart Way not to use personal data for marketing purposes by sending a letter to support@smartway.pro.

4.2. The Client has the right to provide access to the Service to additional Administrators/Users.

5. Security of personal information.

5.1. Smart Way takes the necessary legal, organizational and technical measures or ensures their adoption to protect Personal Information from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as other illegal actions in relation to Personal Information, including, but not limited to:

  • uses RSA encryption in the Smart Way system;
  • protects authorized sessions;
  • constantly improve the methods of data collection, storage and processing;

6. Final provisions

6.1. This privacy policy may be changed unilaterally by Smart Way by posting the terms of the policy in a new version on the Internet at https://smartway.pro/en/privacy-policy.

6.2. Smart Way recommends that you periodically review this Privacy Policy for changes.

6.3. The procedure for using the Smart Way service is governed by the License Agreement.

6.4. In case of any discrepancies between this Privacy Policy and the provisions of the License Agreement, the relationship shall be governed by the provisions of the License Agreement.