Privacy Policy
This document “Privacy Policy” (hereinafter referred to as the “Policy”) is the terms for processing the Personal information by Kirill Labutkin pr Beograd (Registration number: 67010922, Danila Lekića Španca 1, 11077 Belgrade, Serbia) (hereinafter referred to as “KL”).
USER’S CONSENT:
By checking the box “I agree” accompanied with the link to this Policy you (hereinafter also referred to as “User”) with your own free will and for your benefit give your written consent to the processing of User’s Personal Information for the purposes and under the terms and conditions stipulated by this Policy.
1. Terms and Definitions
1.1. Agreement – agreement, executed based on Terms of Service that is posted and/or available on the Internet at: https://vinaty.com/terms-of-service/ as well as any other agreement entered into with the User.
1.2. Website – means automated information system comprised of software programs and/or databases and the Content and available on the Internet at network address in the following domain (including subdomains): https://vinaty.com/
1.3. Services means services that KL provides to User under the Agreement through the use of the functionality of the Website.
2. General Provisions
2.1. This Policy is an integral part of the Agreement as well as other agreements, when it is expressly stipulated by the terms and conditions thereof. Therefore, when executing the above said agreements by methods defined therein including by registration with and/or using the Website you fully accept the terms of this Policy.
2.2. Methods of processing of Personal Information include actions (operations) or a combination of actions (operations) with Personal Information as follows: collection, recording, systematization, storage, updating (refreshment, modification), extraction, use, transfer (provision, access) including transfer to the territories of other countries, depersonalization, blocking, deletion, destruction in the purposes established by this Policy with/without the use of automated facilities.
2.3. The terms and definitions stipulated by the Terms of Service are used herein, as well as other agreements entered into with the User, unless otherwise stipulated by this Policy or follows from the merits thereof. In other cases, the terms used in the Policy shall be interpreted in accordance with the applicable laws, the business practice, or scientific doctrine.
3. Personal Information
3.1. Personal information in this Policy means as follows:
3.1.1. Information that the User provides about him/her on registration or authorization, as well as during further use of the Website and/or the Services, including personal data of the User.
3.1.2. Data transmitted in a depersonalized form in automatic mode, depending on the settings of the User’s software.
3.2. KL is entitled to establish requirements for the composition of the User’s Personal Information, which are mandatory for the use of the Website and/or the Services. If certain information is not marked by the KL as mandatory, it is provided or disclosed by the User at his/her discretion.
3.3. When being registered on the Website, the User shall provide in the mandatory manner: email, password, name, last name.
Upon payment, the user provides information about the company, including the company name, legal and physical addresses, and any other information necessary to complete the transaction and provide the services, which does not constitute personal data.
When paying as an individual, the user must provide personal billing details, such as address, contact information (phone, email), and any other data required to complete the transaction.
When submitting request through the contact form User provides: name, email.
When subscribing to the newsletters User provides email.
3.4. KL will not verify whether the User has the necessary consent for the processing of the provided Personal Information in accordance with this Policy, believing that the User acts in good faith, carefully and makes every effort to obtain all necessary agreements of the subjects of personal data.
3.5. The User understands and accepts the possibility of using third party software in the Website; as a result, such third party can receive and transmit the data in a depersonalized form as stipulated in the paragraph 3.1.2 hereof.
The aforementioned third party software includes the following analytics and advertising services:
• ‘Google Analytics’ that collects and processes data according to privacy policy available at: https://policies.google.com/privacy;
The above mentioned list of the third party software is not limiting. KL may use other similar services (software) and/or cease the use of the listed one.
The scope and conditions for collecting impersonal data by using third party software are determined directly by its titleholders and may include:
• browser data (type, version, cookies);
• operating system data (type, version, screen resolution);
• query data (time, source, IP address).
• other impersonal information about User’s activity on the Website.
The scope and conditions for collection and use of impersonal data by these services are determined directly by these services’ providers and governed by the relevant policies available at their websites.
Accepting this Policy as well as applying certain settings in his/her software including settings of device’s operating system, the User agrees with conditions for collection and use of data by the providers of above listed software services.
4.
4.1. Cookies are small text files placed on your device that are created by the websites you visit or by certain emails you open. Cookies are used to improve your user experience, enable functionality on the website, facilitate site security and provide the business with marketing information about the site’s visitors. Cookie text files comprise both numbers and letters and are saved into special areas in the memory of your computer or mobile device. For further reading on cookies and their use please visit: https://ico.org.uk/global/cookies/ or https://www.allaboutcookies.org/
4.2. The KL use cookies to provide the functionality of the Website and/or the Services, to personalize content and ads and to analyze our traffic. The Website issues cookies upon User’s visiting, unless the User has changed cookie settings in his/her browser to refuse cookies. Please note that with cookies switched off, substantial parts of the Website and/or Services will not be made available to you; such as a User account, where login functionality will be unavailable.
4.3. KL does not use cookies to collect personal identifiable information about you. The cookies that we use collect solely anonymous information that is used to optimize our Website and the Services. We also may share information about your use of our Website with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services.
5. Legal basis of processing of Personal information
The legal basis on which KL relies for the use of Personal information includes:
5.1. Processing of Personal information where User has given consent for one or more specific purposes;
5.2. Processing of Personal information that is necessary for performing a contract to which User is a party;
5.3. Processing of Personal information that is necessary for pursuing the WL’s legitimate interests. Specifically, the WL’s legitimate interests consist of ensuring safety and improving functionality of the Website; of data analysis; of protection of the KL and the Users from fraud.
6. Policy with regard to children
6.1. KL does not intentionally collect personal data from children younger than 16, it does not request it and does not allow them to use the Website. Persons under 16 are not allowed to provide personal information including name, address, telephone number and e-mail. If KL gets to know that the information was collected from a child under 16, KL shall immediately delete such information. If you think we could have obtained any information from a child or about a child under 16, please, contact us through e-mail indicated below.
7. Purposes for Personal Information Processing
7.1. KL performs processing, including collection and storage only personal data that is required for entering into and executing agreements with the User.
7.2. KL is entitled to use the Personal Information for the following purposes:
7.2.1. Entering into the Agreement on use of the Website and/or the Services;
7.2.2. Fulfillment of obligations under the Agreement, including provision the User with access to the Website and/or the Services;
7.2.3. Providing communication with the User for the purpose of support and improving the quality of the Website and/or the Services, including by way of notification with the involvement of third parties;
7.2.4. Marketing, statistical and other research based on depersonalized data from the analytics systems stipulated in the paragraph 3.6. hereof for the purpose of improvement of the Website and/or the Services.
7.2.5. Targeting of advertising and/or informational materials based on depersonalized data from the analytics systems stipulated in the paragraph 3.6. hereof.
8. User’s Rights to User’s Personal Information
8.1. Subject to specific provisions of applicable law, the User has the right:
8.1.1. to be informed about the collection and use of his/her personal data.
8.1.2. to access his/her personal data and have it corrected if it is wrong or incomplete.
8.1.3. to restrict the processing of his/her personal data where the accuracy of the personal data is contested, where the processing is unlawful, and where KL no longer needs the personal data for the purposes for which KL has processed it.
8.1.4. to object to the processing of his/her personal data and also restrict its processing in those instances where KL undertook processing of it in carrying out a task in the public interest or where necessary for our legitimate interest where there is no compelling reason for its continued processing.
8.1.5. to withdraw consent that User had given to the collection and processing of his/her personal data at any time. If User does withdraw his/her consent to the collection and processing of personal data, that withdrawal shall not affect the lawfulness of any processing by KL that is based on the consent User had given before he/she withdrew it.
8.1.6. to obtain the deletion of his/her personal data when it is no longer relevant to the purposes for which it was collected or processed, when User has withdrawn consent and there is no basis for us to continue processing, when User has objected to further processing and there is no compelling interest for continued processing, and when the data was unlawfully processed.
8.1.7. not to be a subject to a decision based solely on automated processing, including profiling, which produces legal affects concerning User or similarly affecting User, except where there is a lawful basis for continued processing.
8.1.8. to receive personal data in a structured, commonly used, and machine readable form for the purpose of data portability in those instances where KL processes by automated means personal data that User has provided.
8.2. These rights may be exercised by using the tools KL offers on the Website or by contacting KL with specific request through the methods described below. KL will address any such requests in a timely manner and according to applicable law. In certain cases, KL may ask User to verify identity before acting on the User’s request. If User is unsatisfied with KL’s response, the User may refer his/her complaint to the relevant supervisory authority in User’s jurisdiction.
9. Personal Information Storage Retention
9.1. All Personal Information that is collected will be stored only as long as is necessary to accomplish the purpose for which it is collected, and/or as long as is permitted or required by applicable law. Periodically, KL will review its data processing systems to determine whether or not the purposes for the collection and processing of User’s personal data remain valid. That determination will be based on factors that include, but are not limited to, whether or not you are still in contact with WL, whether or not any requests made by User from KL have been fulfilled (including any follow-up tasks), whether or not there is a contractual relationship between User and WL, and whether or not there is a contractual or legal basis for continuing to retain User’s personal data. Based on that review and any notifications received from data subjects, KL will update its systems.
10. Requirements for the Personal Information Protection
10.1. KL stores the Personal Information and provides its protection against unauthorized access and distribution in accordance with internal terms and regulations.
10.2. With regard to the User’s Personal Information, its confidentiality is protected, except for the publicly available information and other cases when the technology of the Website and/or the Services provided on its basis or the configuration of the User’s software provides for an open exchange of information with other users of the Website or with any Internet users.
11. Transfer of the Personal Information
11.1. KL is entitled to transfer Personal Information to third parties in the following cases:
11.1.1. The User expressed his/her consent to such actions including when the User applies the settings of the software that specifically allow or do not limit the provision of certain information;
11.1.2. The transfer is performed as the functionality of the Website and/or necessary in the context of performing the Services;
11.1.3. In connection with use of the services of third party providers by the WL. Such third party providers receive Personal Information solely for the purposes of rendering services to KL. Specifically, KL may transfer the User’s name and email and to ‘Zoho’ help desk service that collects and processes data according to the privacy policy available at https://www.zoho.com/privacy.html; to ‘MailChimp’ electronic mail-out service that collects and processes data according to the privacy policy available: https://mailchimp.com/legal/privacy/
11.1.4. In connection with use on the Website of the third party software for collection and processing of User’s data. Specifically, KL may use the third party software for collection and processing of User’s data according to clause 3.6. of this Policy.
11.1.5. Due to the transfer of the Website to the possession, use or property of a third party, including the assignment to such third party of rights under the contracts concluded with the User;
11.1.6. Upon request of a court or other state authority within the procedure established by law;
11.1.7. To protect the rights and legitimate interests of KL in connection with User’s failure to comply with the agreements entered into with the User.
12. Amendments to and deletion of the Personal Information
12.1. The User is entitled at any time to independently edit the Personal Information in his/her account with the Website.
12.2. The User is entitled to delete his/her own account on the Website unassisted or to exercise other rights related to the processing of his/her personal data by sending to KL a request at the address indicated below.
13. Amendments to the Privacy Policy
13.1. This Policy may be amended or terminated unilaterally by KL without prior notice to the User. The new version of the Policy becomes effective after posting on the KL’s Website, unless otherwise provided for by the new version of the Policy.
13.2. The current version of the Policy is on the WL’s website at: http://vinaty.com/privacy-policy/
14. WL’s Details:
Kirill Labutkin pr Beograd (Serbia)
Registration number: 67010922
Belgrade, Serbia
Any questions related to this Policy can be mailed to support@vinaty.com
The representative of Kirill Labutkin pr Beograd (Serbia) in European Union is representative@vinaty.com
The current version of the Policy of 16.09.2024