WEBSITE PRIVACY POLICY

This privacy policy (hereinafter referred to as the Policy) is an integral part of the User Agreement posted on the Internet at the network address https://moduse.com/user-agreement and determines the procedure for processing Personal data and defines the procedure for processing Personal data and measures to ensure the security of Personal data taken by [company name], legal address: [full address of registration of the company], operating on the basis of a license: [license number] in relation to the website on the Internet via the network address https://moduse.com/, as well as in relation to the MODUSE mobile App hosted on the App Store and Google Play platforms.

1. TERMS

1.1. Company – [name of company], legal address: [full address of registration of the company], operating on the basis of a license: [license number], organizing and controlling the processing of Personal data, as well as determining the purposes of processing Personal data, the composition of Personal data to be processed, actions (operations) performed with Users’ Personal data.

1.2. Sources of Personal data:

1.2.1. Website (the definition is established in clause 1.9. section 1 of this Policy);

1.2.2. App (the definition is established in clause 1.7. section 1 of this Policy);

1.2.3. Emails, text messages and other electronic messages (records and copies of correspondence (including correspondence by email, chats, instant messengers in which there is the Company profile);

1.2.4. Another social media pages of the Company, including, but not limited to Facebook, Twitter or Instagram;

1.2.5. Surveys conducted by the Company;

1.2.6. Advertising (the result of the User’s interaction with the Company’s advertising on other websites and/or Apps).

1.3. Processing of Personal data – any action (operation) or set of actions (operations) performed using automation tools or without the use of such means with the User’s Personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), deletion, destruction of the User’s Personal data.

1.4. Personal data –is an information relating to a specific or identified User of the Site and / or App, namely:

– Information that directly reveals the User’s identity:

1.4.1. Name (including surname and patronymic (if available)), nickname;

1.4.2. Gender;

1.4.3. Country;

1.4.4. Email address;

1.4.5. Contact phone number

1.4.6. Records and copies of correspondence (including correspondence by email, chats, instant messengers in which there is the Company profile), in case of communication between the User and the Company;1.4.7. Information provided as part of the User’s interaction with the Company through other social networks (including, but not limited to, Facebook, Twitter or Instagram of the Company), support service for general questions, complaints, requests for help/services, including but not limited to information specified in paragraphs. 1.3.1., 1.3.3 – 1.3.5. clause 1.3. Section 1 of this Policy;1.4.8. Information that is provided for surveys that allow for feedback and help the Company improve;

1.4.9. Information received by the Company as a result of the User’s interaction with the Company’s advertising on other sites and/or Apps;

1.4.10. ID.

-Information that does not directly reveal the User’s identity:

1.4.11. Geolocation;

1.4.12. Language used;

1.4.13. Cookies (small files stored in the memory of the User’s device, designed to personalize the User’s activity and behavior in the App and stores).

At the same time, Personal data, within the meaning of this Policy, does not include data that directly or indirectly disclose information about the User’s family, the User’s ethnic origin, political or philosophical views of the User, religious beliefs of the User, criminal record, as well as biometric data or any data relating to such in accordance with the Law, including health, physical, psychological, mental, genetic or sexual state of the User, including information, related to the provision of medical services to the User, which disclose the User’s health status.

1.5. User – is a subject of Personal data who provides the Company with his Personal data as part of the use of the Site and / or App.

1.6. Providing Personal data – actions aimed at the User disclosing Personal data to the Company by agreeing to this Policy.

1.7. App – mobile App “MODUSE”, hosted on the App Store and Google Play platforms.

1.8. Distribution of Personal data – actions of the Company aimed at disclosing the User’s Personal data, namely: name (nickname), to an unlimited number of persons or to familiarize themselves with the User’s Personal data, namely: name (nickname), to an unlimited number of persons, including the publication of Personal data User on the Site and/or App with the consent of the User.1.9. Website – is a web resource located on the Internet at the network address https://moduse.com/.1.10. Cross-border transfer of Personal data – 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 entity, which is carried out with the additional consent of the User.

2. GENERAL

2.1. The Company sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a man and a citizen when processing his Personal data, including the protection of the rights to privacy, personal and family secrets.

2.2. Please read this Policy carefully. Using the services of the Site and / or the App means the unconditional consent of the User with this Policy and the terms of processing his Personal data specified therein.

2.3. In case of questions or concerns regarding this Policy or Personal data, contact the Company using the contact information specified in the section “How to contact us?”.

2.4. In case of disagreement with this Policy, do not use the Site and / or the App, continued use of the Site and / or the App means consent to this Policy.

3. PRINCIPLES USED IN THE POLICY

3.1. Legality.

The processing of Personal data is carried out on a legal and fair basis based on the consent of the User. However, the provision of the User’s consent is not necessary for the Administrator in the following cases: conclusion of an agreement, amendment or termination of an agreement with the User; the User has made Personal data publicly available; to protect the interests of the User, including to defend legal rights or within the framework of judicial or security procedures.

3.2. Specificity and appropriateness.

The processing of Personal data is limited to achieving the specific purposes set out in Section 4 of this Policy. Processing of Personal data that is incompatible with the purposes set out in Section 4 of this Policy is not permitted. Excessive processing of Personal data in relation to the stated purposes of their processing is not permitted.

3.3. Transparency.

Personal data shall be processed solely on the basis of the User’s consent, except for cases specified in paragraph 3.1. Section 3 of this Policy.

3.4. Relevance.

When processing Personal data, the accuracy of Personal data, its sufficiency, and, where necessary, relevance in relation to the purposes specified in Section 4 of this Policy are ensured. The Company shall take the necessary measures and/or ensure their adoption to delete or clarify incomplete or inaccurate data.

3.5. Limited storage period.

Personal data shall be stored in a form that allows the User to be identified, no longer than required by the purposes specified in Section 4 of this Policy.

4. PURPOSES OF PERSONAL DATA PROCESSING

Purpose of processing Personal data	Method of processing Personal data	Volume of processed Personal data
Registration on the Site and/or in the App	The Company collects, records, stores and systematizes Personal data, including by automated means. The processing of such Personal data is carried out until the termination of this Policy.	·             Gender; ·             Email address.
Identification on the Site and/or in the App		·             Gender; ·             Email address.
Establishing and maintaining communication between the User and the Company,	The Company collects, records, systematizes, accumulates and uses Personal data to send notifications to the User’s e-mail address. The processing of such Personal data is carried out until the termination of this Policy/.	·             Full name; ·              Email address; ·             Contact phone number.
Analysis of the consumer market taking into account the User’s Personal data		·             Email address.
Sending advertising messages; targeting advertising materials		·             Full name; ·             Email address; ·             Contact phone number.
Improving the quality of service for Users		·              Cookies

5. RIGHTS AND RESPONSIBILITIES OF THE COMPANY AND USERS

5.1. The Company has the right to:

5.1.1. Receive from the User the Personal data necessary for the implementation of the purposes set out in Section 4 of this Policy;

5.1.2. In the event that the User revokes their consent to the processing of Personal data, as well as sends an appeal with a request to stop the processing of Personal data, the Company has the right to continue processing Personal data without the User’s consent in the cases established by paragraph 3.1. Section 3 of this Policy.

5.2. The Company is obliged to:

5.2.1. Provide the User, at their request, with information regarding the processing of their Personal data;

5.2.2. Stop processing the User’s Personal data in the event that the User revokes their consent to the processing of Personal data, as well as sends an appeal with a request to stop the processing of Personal data, except for the cases established by paragraph 3.1. Section 3 of this Policy;

5.2.3. Provide the User’s Personal data to regulatory authorities in the manner prescribed by the legislation of the United Arab Emirates;

5.2.4. Organize the processing of the User’s Personal data in the manner prescribed by the current legislation of the United Arab Emirates;

5.2.5. Respond to requests and inquiries from the User and his legal representatives in accordance with the requirements of the legislation of the United Arab Emirates;

5.2.6. Publish or otherwise provide unlimited access to this Policy regarding the processing of Personal data;

5.2.7. Take legal, organizational and technical measures to protect Personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of Personal data, as well as from other illegal actions in relation to the Personal data of Users.

5.3. The User has the right:

5.3.1. Receive confirmation that the Company is processing the User’s Personal data, receive a copy of their Personal data stored by the Company;

5.3.2. Make changes, corrections and additions to their Personal data if they are incomplete or inaccurate, or have become outdated (for example, if the User has changed their name, email address or contact phone number);

5.3.3. Restrict the processing of his/her Personal data by the Company in the following cases:

– Temporarily for the period while the User disputes the accuracy of their Personal data;

– Temporarily for the period when the User objects to the correctness of his/her Personal data, if the User’s Personal data has been illegally processed and the User demands to restrict the processing of the Personal data, rather than delete it;

– The Personal data provided by the User to the Company is no longer needed for the purposes set out in Section 4 of this Policy;

5.3.4. Request the deletion of their Personal data, except for the cases set out in paragraph 3.1. Section 3 of this Policy;

5.3.5 Object to the processing of his/her Personal data;

5.3.6. Revoke consent to the processing of Personal data by sending a notice to the email address of the Company specified in the section “How to contact us?” with the note “Revocation of consent to the processing of Personal data”;

5.4. The User is obliged to:

5.4.1. Notify the Company of clarification (update, change) of his/her Personal data by sending a notice to the email address of the Company specified in the section “How to contact us?” with the note “Update of Personal data”.

6. GUARANTEES OF THE COMPANY

6.1. The security and confidentiality of Personal data processed by the Company is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of the legislation of the United Arab Emirates in the field of Personal data protection.

6.2. The Company ensures the safety and confidentiality of Personal data and takes all possible measures to prevent unauthorized persons from accessing Personal data.

6.3. The User’s Personal data will never, under any circumstances, be transferred to third parties, except for the cases specified in paragraph 3.1. Section 3 of this Policy or if the User has given consent to the transfer of data to a third party.

6.4. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by the said persons in accordance with their User Agreements and Privacy Policies. The Company is not responsible for the actions of third parties, including the suppliers of goods and services specified in this paragraph.

7. DISPUTE RESOLUTION

7.1. Before applying to the court for disputes arising from the relationship between the User and the Company, it is mandatory to file a claim (a written proposal for voluntary settlement of the dispute).

7.2. The recipient of the claim, within 14 (Fourteen) calendar days from the date of receipt of the claim, shall notify the claimant in writing of the results of the consideration of the claim.

7.3. If no agreement is reached, the dispute will be referred for consideration to court at the location of the Company.

8. HOW TO CONTACT US?

If you have any questions regarding this Policy, please contact:

8.1. By email: info@moduse.com

8.2. By phone:

8.3. By postal address:

9. FINAL PROVISIONS

9.1. This Policy will reflect any changes to this Policy made by the Site Company. The Policy is valid indefinitely until it is replaced by a new version.

9.2. The current version of the Policy is freely available on the Internet at [site page with the policy].

9.3. The current legislation of the United Arab Emirates shall apply to this Policy and the relationship between the User and the Site Company.

9.4. The condition for termination of the processing of Personal data may be the achievement of the goals specified in Section 3 of this Policy, the expiration of the User’s consent, the User’s withdrawal of consent or a request to terminate the processing of Personal data, as well as the detection of unlawful processing of Personal data.

9.5. The Company is obliged to notify Users about the implementation of activities for the cross-border transfer of Personal data by amending this Policy.