IPLAND Privacy Policy

Version 3.0

Updated March 28, 2024

IPLAND respects your right to privacy. This privacy policy has been developed to inform you about the privacy practices followed by IPLAND in connection with its websites, products, and services.

This privacy policy will inform you about what data is collected, how we use such data, where data is processed, how you may opt-out of your data being used, the security provisions around storing your data, and how to correct or update your data.

1. General provisions

We process your personal data only if one of the conditions specified in Article 6 of the GDPR is met, including, but not limited to:

• You have consented to the processing of your personal data.
• Processing is necessary for the purpose of providing services to you.
• Such processing is required by the laws of the countries in which you are located.

We take seriously the security of the personal data of our clients, potential clients and other persons who contact us, therefore we strive to protect the confidentiality of your personal data. The Company's senior management undertakes to take all necessary measures to prevent the misuse of your personal data that becomes known to us. We will process your personal data in strict accordance with the requirements of applicable Law and only if there are legal grounds for such processing.

You are not required to provide us with personal information, but without certain information about you we may not be able to provide you with some of our services. To the extent that we control how we collect your personal data and determine the purposes for which that personal data is used, the Company is the “data controller” for the purposes of the GDPR, ISO 27701:2019 and other applicable European data protection legislation, as well as the “owner” personal data” within the meaning of the Law.

What personal dataare we processing? When you use our service (Services), we may process personal data depending on how you interact with us and the Services, the choices you make, which elements of the Service and which features you use.

Do we process sensitive personal data? We do not process sensitive personal information data.

Do we receive any information from third parties? We do not receive any information from third parties.

How we process your personal information data? We process your personal data to provide, improve and administer our services, communicate with you, maintain security and prevent fraud, and comply with the Law. We may also process your personal data for other purposes with your consent. We process your personal data only if we have compelling legal reasons to do so.

In what situations and with what parties do we share personal information? data? We may share personal data in situations specified by Law and with third parties specified by Law.

How we store your personal information data? We use organizational and technical processes and procedures to protect your personal data. ​However, neither electronic transmission over the Internet nor information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal or change your and personal data .

What are your rights?

You may instruct us to provide you with any information about the personal data we hold about you. We reserve the right to refuse to provide information at your request, within the limits of applicable law.

You have the right to withdraw your consent to the processing of personal data at any time, without affecting the lawfulness of the processing that was based on the consent before its withdrawal.

You have the right to send us a request to correct or erase personal data, or to restrict the processing of personal data about you and to object to such processing.

You have the right to instruct us not to process your personal data for automated purposes or for marketing purposes.

Depending on your geographic location, applicable privacy laws may mean that you have additional rights with respect to your personal information data.​

How can you exercise your rights?

The easiest way to exercise your rights is to:

• Visit our website https://ipland.com.ua
• Write a request to the effie> Support Service of IPLAND support@ipland.global
• Make a phone call
  • +38 095 286 19 89
  • +38 067 623 76 73
  • +38 044 333 49 94

We will consider any request and take action in accordance with applicable data protection laws.

2. What information do we collect

2.1. Personal information we collect

We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us in order to access the effie Service, express an interest in obtaining information about us or our products and services, when you participate in activities within the Services, or otherwise when you contact us.

2.2. Personal data provided by you

The personal information we collect depends on the context of your interactions with us and the effie> Service , the choices you make, and the products and features you use. The personal information we collect may include the following:

• Surnames, names
• Phone numbers
• Email addresses
• Job Titles
• Usernames
• Contact or authentication details
• Passwords

2.3. Sensitive information

We do not process sensitive personal data.

2.4. Application data

If you use our effie> Service (apps), we may also collect the following information if you choose to grant us access or permission:

• Geolocation information . We may request access to or permission to track geolocation information from your mobile device, either continuously or while you use our mobile application, in order to provide certain location-based services. If you want to change our access or permission, you can do so in your device settings.
• Mobile device access. We may request access to or permission to use certain features of your mobile device, including camera, storage, and other features. If you want to change our access or permissions, you can do so in your device settings.
• Mobile device data. We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system information, system version and configuration, device and application identification numbers, browser type and version, Internet service provider hardware model and/or mobile operator, and Internet Protocol (IP) address (or proxy server). If you use our application(s), we may also collect information about the telephone network associated with your mobile device, the operating system or platform of your mobile device, the type of mobile device you use, the unique identifier of your mobile device, and information about the features of our the application(s) you accessed.
• Push notifications. We may request to send you push notifications related to your account or certain features of the application(s).

This information is primarily needed to maintain the security and operation of our application, for troubleshooting purposes, and for internal analytics and reporting purposes.

All personal information you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

3. How do we process your personal data?

We process your personal data to provide, improve and administer our services, communicate with you, maintain security and prevent fraud, and comply with the law. We may also process your personal data for other purposes with your consent.

We process your personal data for a variety of reasons depending on how you interact with our effie> Service , including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your personal data so that we can create an account for you and maintain your account.
• To provide and facilitate the provision of services to the user. We may process your personal data in order to provide you with the service you have requested.
• To respond to/provide support to users. We may process your personal data to respond to your requests and resolve any potential problems you may have with the effie> Service .
• To send you administrative information. We may process your personal data to send you information about our products and services, changes to our terms and conditions and policies, and other similar information.
• To fulfill and manage your orders. We may process your personal data to fulfill and manage your requests made through the effie> Service.
• To ensure communication between users. We may process your personal data if you choose to take advantage of any of our offers that allow you to communicate with another user.
• To preserve or protect vital human interests. We may process your personal data if it is necessary to save or protect a person's vital interests, for example to prevent harm.

4. What legal grounds do we rely on when processing your personal data?

We process your personal data only when necessary and have a legal basis for doing so (i.e. a legal basis) to do so in accordance with applicable law, for example, with your consent, to comply with laws, to provide you with services to conclude/ to fulfill our contractual obligations, to protect your rights or to pursue our legitimate business interests.

The General Data Protection Regulation (GDPR), UK GDPR, ISO 277001:2019 require us to explain what legal basis we rely on when processing your personal data. Therefore, we may rely on the following legal grounds to process your personal data:

• Agreement . We may process your personal data if you have given us permission (i.e. consent) to use your personal data for certain purposes. You can withdraw your consent at any time.
• Execution of the contract. We may process your personal data where we believe it is necessary to fulfill our contractual obligations to you, including the provision of our effie> Service , or at your request before entering into a contract with you.
• Legal obligations. We may process your personal data where we believe it is necessary to comply with our legal obligations, for example to cooperate with law enforcement authorities or regulatory agencies, to exercise or defend our legal rights, or to disclose your information as evidence in legal proceedings in which we Let's participate.
• Vital interests. We may process your personal data where we believe it is necessary to protect your vital interests or the vital interests of a third party, for example in situations involving a potential threat to the safety of any person.

5. When and with whom do we share your personal data?

We may share your personal information in certain situations described in this section and/or with the following third parties.

We may need to share your personal data in the following situations:

• Business transfer. We may share or transfer your personal information in connection with or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Maps Platform APIs . We may share your personal information using certain Google Maps Platform APIs (e.g., Google Maps API, Places API).

6. Do we use COOKIES and other tracking technologies?

We may use cookies and other tracking technologies to collect and store your personal information.

We may use cookies and similar tracking technologies (such as web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

7. How long do we store your personal data?

We retain your personal information for as long as necessary to fulfill the purposes outlined in this privacy notice, unless otherwise required by law.

We will only retain your personal data for as long as necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

We do not store your personal data longer than the period of time that users have an account with us.

Unless we have an ongoing legitimate business need to process your personal information, we will delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate them from any further processing until removal is possible.

In any case, we do not store your personal data for more than 10 years.

8. How do we store your information?

We strive to protect your personal data through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal data we process. However, despite our security measures and efforts to protect your information, neither electronic transmission over the Internet nor information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will persons will not be able to breach our security and improperly collect, access, steal or change your personal data. Although we will do our best to protect your personal information, transmission of personal information to and from our effie> Service is at your own risk. You must access the effie> Service only in a secure environment.

9. Do we collect information about minors?

We do not knowingly collect personal information from or provide services to people under 18 years of age.

We do not knowingly solicit personal information from children under 18 years of age. By using the effie> Service , you confirm that you are at least 18 years of age. If we learn that personal information from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of information that we may have collected from children under 18 years of age, please contact us at IPLAND Help Desk support@ipland.global/ .

10. What are your privacy rights?

In some regions, you have rights that allow you greater access and control over your personal information. You may review, change or terminate your account at any time. In addition, you have the right:

• request access to and obtain copies of your personal information,
• (ii) request correction or deletion;
• (iii) restrict the processing of your personal information;
• (iv) if applicable, transfer data; And
• (v) not be subject to automated decision making.

In some regions (for example, in Ukraine), you have certain rights in accordance with current data protection legislation (Article 8 of the Law of Ukraine “On the Protection of Personal Data”). These include the right to:

• Information about your personal data - You can contact us at any time to receive information about:
  • whether we process your personal data;
  • for what purpose;
  • sources of personal data collection;
  • where we process your personal data;
  • what categories of personal data we process;
  • who is the recipient of your personal data and information about their transfer;
  • Do we use automated decision making and its mechanism, if so.
  • Access to your personal data - You can access all of your personal data that we process.
  • Change of data - if information about you is or has become inaccurate or incomplete, you have the right to demand that the data be corrected or supplemented.
  • Withdrawal of consent - You can withdraw your consent to data processing at any time and this will not affect the lawfulness of processing based on consent before its withdrawal.
  • Destruction of data - You can request the destruction of data if it is inaccurate, or processed illegally, or if otherwise provided by law.
  • Restriction of processing - You may request that we restrict what we do with respect to your personal data.
  • Objection - You have the right to object to some of the actions we take with respect to your personal data for specific reasons related to your personal situation. If, despite your objection, we find that there are compelling legal grounds for processing that override your interests, rights and freedoms, or grounds for the establishment, exercise or defense of legal claims, we will continue to process the data raised in the objection. , to the extent necessary. If you do not agree with this assessment of the situation, you can exercise your right to file a complaint with the appropriate government agency (information below).
  • Complaints to the relevant government authority - in connection with our actions as the controller (owner) of your personal data, you have the right to lodge a complaint with the relevant regulatory authority or court. For Ukraine, such a body is the Commissioner of the Verkhovna Rada of Ukraine for Human Rights. You can find his contacts at https://www.ombudsman.gov.ua/.

In certain circumstances, you may also have the right to object to the processing of your personal data. You may make such a request by contacting us at the contact information provided in the HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

We will consider any request and take action in accordance with applicable data protection laws.

If you are located in the EU or UK and believe that we are unlawfully processing your personal data, you also have the right to lodge a complaint with the data protection authority of an EU member state or the UK data protection authority. If you are located in Switzerland, you can contact the Federal Data Protection Commissioner. We encourage you to first contact us at the addresses provided in the HOW CAN YOU CONTACT US ABOUT THIS NOTICE? section.

10.1. Withdrawal of your consent

Where we rely on your consent to process your personal data, which may be express and/or implied consent depending on applicable law, you have the right to withdraw your consent at any time. You may withdraw your consent at any time by contacting us at the contact details provided in the section HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

Please note, however, that this will not affect the lawfulness of processing prior to withdrawal of consent or, where applicable law permits, it will not affect processing of your personal data carried out on lawful grounds other than consent.

10.2. Account Information

If you would like to review or change the information in your account or terminate your account at any time, you may:

• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and your personal information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms and/or satisfy applicable legal requirements. If you have questions or comments regarding your privacy rights, you can write to us at: IPLAND effie> Help Desk <support@ipland.global> .

11. Do Not Track Controls

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track feature. 'DNT'), which you can activate to indicate your desire not to have data about your online activities tracked or collected. There is currently no single technology standard for recognizing and implementing DNT signals. Therefore, we do not currently respond to browser DNT signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted in the future that we must follow, we will inform you about such practices in a revised version of this privacy notice.

12. Are we making changes to the personal data privacy policy?

Yes, we will update our privacy policy as necessary to remain compliant with applicable laws.

We may update our privacy policy from time to time. The updated version will be indicated by an updated "Approved" date and the updated version will be effective as soon as it becomes available. If we make material changes to our privacy practices, we may notify you either by prominently posting notice of such changes or by directly sending you a notification. We encourage you to review our privacy policy frequently to stay informed about how we are protecting your information.

13. How can you contact us regarding our personal data privacy policy?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at pd@ipland.global, or by contacting with us by mail:

IPLAND , Ukraine, Kiev, 03115, Hetman Kirill Razumovskyi st., 27, phone: +380443648828

If you have additional questions or comments, you can also contact us by mail at the following corporate address:

IPLAND, Ukraine, Kyiv, 03115, Hetman Kirill Razumovskyi st., 27, phone: +380443648828

14. How can you review, update or delete the information we collect about you?

Subject to the applicable laws of your country, you may have the right to request access to, change or delete the personal data we collect about you. To request to review, update or delete your personal information, please contact IPLAND's effie> Help Desk <support@ipland.global>.