Privacy Policy
This personal data processing policy determines the procedure for their processing and measures to ensure the security of personal data taken
https://kleexfly.com
(hereinafter referred to as the Platform).
1.1. The Platform sets as its most important goal and condition for the performance of its activities the observance of human rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal data and trade secrets.
1.2. This Platform's policy concerning the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Platform can receive about visitors of the website
https://kleexfly.com
2. Basic terms used in the Policy
2.1. Automated processing of personal data - processing of personal data via computer technology.
2.2. Blocking of personal data is a temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data).
2.3. Website - a set of graphic and informational materials, as well as computer programs and databases that ensure their availability in the Internet at the network address
2.4. Personal data information system - a set of personal data contained in databases, and information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a particular User or other subject of personal data.
2.6. Processing of personal data - any action or set of actions performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification, extraction, using, distribution, accessing, depersonalization, blocking, deletion, destruction of personal data.
2.7. Platform - a legal person which independently processes personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and actions performed with personal data.
2.8. Personal data - any information referring directly or indirectly to a particular User of the website
https://kleexfly.com
2.9. Personal data permitted by the subject of personal data for distribution - personal data, access to which is provided by the subject of personal data to an unlimited number of persons by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data allowed for distribution).
2.10. User - any visitor to the website
https://kleexfly.com
2.11. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or familiarizing with personal data of an unlimited number of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data is the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal person.
2.14. Destruction of personal data - any actions as a result of which personal data is irretrievably destroyed with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) material carriers of personal data are destroyed.
3. Basic rights and obligations of the Platform
3.1. The Platform has the right to:
– receive reliable information or documents containing personal data from the subject of personal data;
– continue processing personal data without the consent of the subject of personal data in the event of withdrawal of consent to the processing of personal data by the subject of personal data if there are grounds specified in this Policy on personal data;
– independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by this Policy on personal data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by other laws.
3.2. The Platform shall:
– provide the subject of personal data, at his request, information regarding the processing of his personal data;
– organize the processing of personal data in the manner prescribed in this Policy;
– respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of this Personal Data Policy;
– report to the authorized body for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 30 days from the date of receiving such a request;
– publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
– take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other illegal actions relating to personal data;
– stop transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for in this Personal Data Policy.
4. Basic rights and obligations of subjects of personal data
4.1. Subjects of personal data have the right to:
– receive information regarding the processing of his personal data. Information is provided to the subject of personal data by the Platform in an accessible form, and it should not contain personal data related to other subjects of personal data, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by this Personal Data Policy;
– require the Platform to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures to protect their rights;
– put forward the condition of prior consent when processing personal data in order to promote goods, jobs and services on the market;
– withdraw consent to the processing of personal data;
– appeal in court against illegal actions or inaction of the Platform in the processing of his personal data;
4.2. Subjects of personal data shall:
– provide the Platform with reliable data about themselves;
– inform the Platform about the clarification (updating, changing) of their personal data.
4.3. Persons who have provided the Platform with false information about themselves or information about another subject of personal data without the consent of the latter shall be liable for illegal actions.
5. The Platform may process the following personal data of the User
5.1. Name or designation of the User.
5.2. Email address.
5.3. Phone numbers and messengers.
5.4. Photos.
5.5. The website also collects and processes anonymous data about visitors (including cookie files) via Internet statistics services.
5.6. The above listed data of this Policy are united by the general concept of Personal data.
5.7. Processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Platform.
5.8. Processing of personal data posted in the User's Personal Account.
5.9. The User voluntarily provides the Platform consent to the processing of personal data permitted for distribution.
5.10. The transfer (distribution, provision, access) of personal data permitted by the subject of personal data for distribution shall be terminated at any time at the request of the subject of personal data. This requirement should include a list of personal data, the processing of which is subject to termination.
5.11. Consent to the processing of personal data permitted for distribution ceases to be valid from the moment the Platform receives the corresponding request.
6. Principles of processing of personal data
6.1. The processing of personal data is carried out in a lawful and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, pre-defined and legitimate purposes. It is not allowed to process personal data that is incompatible with the purposes of collecting personal data.
6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes which are incompatible with each other.
6.4. Only personal data that meet the objectives of their processing are subject to processing.
6.5. The content and amount of the processed personal data shall correspond to the stated purposes of processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data, shall be ensured. The Platform takes the necessary measures and/or ensures that incomplete or inaccurate data is deleted or clarified.
6.7. The storage of personal data is carried out in the form that allows to determine the subject of personal data, not longer than required by the purposes of processing personal data. The processed personal data is destroyed or depersonalized upon reaching the objectives of processing or in case of loss of the need to reach these objectives, unless otherwise provided by another agreement.
7. Purposes of the processing of personal data
7.1. The purposes of processing of the User's personal data are:
– informing the User by sending e-mails;
– conclusion, execution and termination of contracts;
– providing the User with access to the services, information and/or materials contained on the website
https://kleexfly.com
7.2. The Platform also has the right to send notifications to the User about new products and services, special offers and various events. The User can always opt out of receiving informational messages by sending an email to the Platform at
kleexfly@gmail.com
with the note “Opt out of receiving notifications about new products and services and special offers”.
7.3. Anonymized data of Users collected via Internet statistics services are used to collect information about the actions of Users on the site, improve the quality of the site and its content.
8. Legal grounds for personal data processing
8.1. The legal grounds for the processing of personal data by the Platform are:
– agreements concluded between the Platform and the subject of personal data;
– regulatory acts in the field of personal data protection;
– Users' consent to the processing of their personal data, to the processing of personal data permitted for distribution.
8.2. The Platform processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website
https://kleexfly.com
or sent to the Platform by e-mail. By filling out the relevant forms or submitting their personal data to the Platform, the User expresses his consent to this Policy.
8.3. The Platform processes anonymized data about the User if it is allowed in the User's browser settings (saving cookies and using JavaScript technology are enabled).
8.4. The subject of personal data independently decides on the provision of his personal data and gives consent freely, voluntarily and in his interests.
8.5. The subject of personal data agrees that the personal data entered by him in his Personal Account (in the Contacts section) is public information and shall be displayed as the Subject's contacts in his advertisements.
9. Conditions of personal data processing
9.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
9.2. The processing of personal data is necessary for the normal functioning of the Platform.
9.3. The processing of personal data is necessary for the performance of the agreement to which the subject of personal data is a party, as well as for the conclusion of an agreement initiated by the subject of personal data or an agreement under which the subject of personal data will be the beneficiary.
9.4. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Platform or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
9.5. The processing of personal data is carried out by an unlimited circle of persons who are granted access by the Subject of personal data or at the request of a representative.
9.6. The processing is carried out of those personal data that are subject to publication or mandatory disclosure.
10. Procedure of collection, storage, transfer and other types of personal data processing
The security of personal data processed by the Platform is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements in the field of personal data protection.
10.1. The platform ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
10.2. The User's personal data shall never, under any circumstances, be transferred to third parties, unless the subject of personal data has given consent to the Platform to transfer data to a third party to fulfill obligations under a civil law contract.
10.3. In case of detection of inaccuracies in personal data, the User can update them independently and make changes in his Personal Account.
10.4. The term for the processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different term is provided for by another agreement. The User may at any time withdraw his consent to the processing of personal data by sending a notification to the Platform by e-mail to the email address of the Platform
kleexfly@gmail.com
marked "Withdrawal of consent to the processing of personal data".
10.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data or the User is obliged to familiarize himself with the specified documents in due time. The Platform is not responsible for the actions of third parties, including the service providers specified in this paragraph.
10.6. The platform, when processing personal data, ensures the confidentiality of personal data.
10.7. The Platform stores personal data in a form that allows identifying the subject of personal data for no longer than is required by the purposes of processing of personal data, unless the period for storing personal data is established by another agreement to which the subject of personal data is a party, beneficiary or guarantor.
10.8. The condition for terminating the processing of personal data may be the achievement of the purposes of processing of personal data, the expiration of the consent of the subject of personal data or the withdrawal of consent by the subject of personal data, as well as the identification of unlawful processing of personal data.
11. List of actions performed by the Operator with the received personal data
11.1. The platform collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
11.2. The platform carries out automated processing of personal data with the receipt or transmission of the received information via information and telecommunication networks or without it.
12. Cross-border transfer of personal data
12.1. Before the start of cross-border transfer of personal data, the Platform shall make sure that the foreign state, acting as personal data recipient, ensures reliable protection of the rights of subjects of personal data.
12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements shall be carried out with the consent of the subject of personal data to the cross-border transfer of his personal data or the execution of an agreement to which the subject of personal data is a party.
13. Confidentiality of personal data
The Platform and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by additional agreements.
14.1. The User can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Platform via e-mail
14.2. This document will reflect any changes in the policy of processing of personal data by the Platform. The policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at
Link