User Agreement http://lalafo.gr/
1. General Terms
- This Agreement stipulates User terms of using the Service http://lalafo.gr/.
- For the purpose of this User Agreement the terms below shall have the following meaning:
- Web Service shall mean Internet-resource (website) located on the Internet at the address http://lalafo.gr/, website applications on the basis of various operating systems and other services, as well as software, design (graphic presentation) of the website, its applications and other services, Data Base, any section (subsection) of the web services, as well as information placed on the web services by the Administration and the Users.
- Administration shall mean Private limited company Yalla Classifieds (YALLA CLASSIFIEDS OÜ), address: Pärnu Road 22, 10141 Tallinn, Estonia registered and acting in accordance with the legislation of Estonia, which shall perform Web Service administration and own all exclusive ownership rights to the Web Service.
- User shall mean any competent individual who has accepted the terms of this Agreement and is using the services offered by the Web Service.
- Personal Account shall mean combination of User data and settings set (placed) by the User. Any User shall have the right to have only one Personal Account.
- User’s Personal Information shall mean information or combined information about the User provided by the User independently during the process of registration or the Web Service usage, including personal data of the User, information which shall be automatically forwarded to the Administration when the Web Service is used, including also IP address, cookie information, information about the User’s browser and other information about the User.
- Information shall mean any information placed by the User or the Administration on the Web Service.
- Spam shall mean bulk, unauthorised mail and/or mail unexpected by the recipients or other mailing of advertising, informational, campaigning or other nature.
- Merchandise shall mean products, works, services, material and technical resources, property and non-property rights.
- Parties to this Agreement shall mean the Administration and the User.
- Any terms and concepts used in this User Agreement that are not indicated in the Terms and Definitions paragraph shall be interpreted in accordance with the content derived from the User Agreement text. Should any differences arise regarding interpretation of a term or a definition used in the User Agreement, the interpretation determined by the Administration shall be applied.
- Usage of materials and services offered by the Web Service shall be governed by the current legislative regulations, as well as by this Agreement.
- By using the services offered by the Web Service, the User shall join this Agreement and accept its terms and obligations to follow instructions on how to use the services of the Web Service (regardless of whether the user is registered on the website or not).
- When the Web Service is used on behalf of a company, such company shall accept this Agreement and its terms.
- The Administration shall have the right to unilaterally alter the terms of this Agreement at any time.
- If the User does not agree with the terms of this Agreement or amendments thereto, the User shall give up access to the Web Service and stop using the services offered by the Web Service.
- The Administration shall offer hereby its Users services on placement and search of advertising with the aid of the services offered by the Web Service.
- Provision of paid services is also regulated by special rules and/or agreements with third parties providing payment processing services.
- The User shall accept the provision that all materials and services of the Web Service, or any part thereof, may be accompanied by advertising. The User shall agree that the Administration shall carry no liability whatsoever and carry no obligations in connection with such advertising.
- Registration on the Web Service is voluntary. Once registered on the Web Service, the User shall gain access to additional services offered by the Web Service. The Administration shall reserve the right to demand at any time that the User confirms data indicated during the registration and to request documentary proof.
- The User shall need to create an account and account password to use the Web Service. The User shall keep the password confidential. The User shall be liable for the actions involving the usage of the email and password, as well as the actions performed in the User’s Personal Account. The User shall have the right to use services of the Web Service solely by logging in with his/her own email and password. While the Web Service works to protect the security of all Users’ contents and accounts, the Web Service cannot guarantee that unauthorized third parties will not be able to defeat security measures. If the User has the grounds to believe that his/her Personal Account has been compromised, the User shall independently change the password. The User should notify the Web Service support immediately of any compromise or unauthorized use of his/her account.
- The Administration cannot guarantee that the User is the person he/she claims to be, or that the information provided by the User during the registration on the Web Service is true.
- The User shall bear liability for the information provided by him/her, while the Web Service shall provide the channel to distribute and publish the User’s data online.
- The User shall not use data provided by another User without the written consent of that User or without approval in any other way to use such data. All information obtained by the User about other Users in connection with using the Web Service may be used solely for entering into and performing transactions related to the Merchandise. Therefore, the User shall not use email address or a phone number of another User with the purpose of direct email marketing or any other delivery of unfavourable electronic messages, as well as for any other illegal acts or actions performed without the other Party’s knowledge and consent.
- The User is advised to interact with other parties using all tools available on the Web Service.
- The Administration shall reserve the right to refuse, at its own discretion, the User’s access to the services in situations where such User violates the terms of this Agreement.
- The Web Service shall have the right to restrict or terminate the User’s access in cases when such User violates other persons’ rights or the current legislation, as well as due to other reasons, at its own discretion.
- The User whose access to the services has been terminated or whose information is not true any longer shall have no right to register again without special permission by the Administration. Neither shall such User have the right to use registration information of another User in order to gain access to the Web Service and its services.
2. Usage of the Web Service. Advertisement Placement
- The Administration shall provide the right to place advertisements on the Web Service to all registered Users upon completion of a special User registration form.
- The User agrees not to take any actions that may be viewed as violating the legislation or regulations of international law, including those in the field of intellectual property, copyright and/or allied rights, as well as any actions that lead or may lead to the violation of normal Web Service operation.
- All transactions related to the Merchandise, works and services shall be entered into between the Users directly. The Web Service shall not serve as the participant and/or the mediator of the transactions entered into by the Users via the Web Service. The Administration shall not control or be held liable for such transactions.
- User’s comments and other entries on the Web Service shall not contradict the legislative requirements and generally accepted moral and ethical norms.
- The Web Service may contain links to third-party websites, advertisers, services, special offers, or other events or activities that are not owned or controlled by the Web Service. The Web Service does not endorse or assume any responsibility for any such third-party sites, information, materials, products, or services. If the User accesses any third party website, service or content from the Web Service, the User does so at his/her own risk and the User acknowledges that the Web Service shall not be held liable for the damage arising out of the User’s use of or access to any third-party website, service or content.
- The Web Service shall carry no liability for the violation of third party rights in connection with the User’s presentation of any information and data.
- The Web Service User shall place Advertisements in accordance with the Web Service instructions and provide reliable and complete information about Merchandise and terms of its realization. The User shall verify information about Merchandise indicated in the Advertisement, and in case of finding false or incomplete data, shall correct or add necessary information in the Advertisement.
- When placing an Advertisement about Merchandise, the User confirms that he/she is authorised to perform actions with regards to such Merchandise as indicated in the Advertisement.
- The User shall confirm that he/she possesses all necessary rights, licenses, permits to place information and data in the Web Service Advertisements, including all patents, trademarks, commercial secret, and intellectual property rights, or possesses appropriate written consent, license or permission given by third parties to use their names, images or any other objects.
- The Web Service shall have the right to request documentary proof from the User and/or additional information regarding the placed Merchandise or regarding the data submitted by the User. The Web Service shall have the right to put publication on hold until such documentation or information is received.
- The User shall have the right to sell on the Web Service any Merchandise belonging to him/her, provided no special permits are required thereto, and provided the current instructions for use are adhered to.
- In order to maintain high quality of services, the Web Service shall reserve its right to limit the number of active User Advertisements on the Web Service, as well as to restrict User’s activity on the Web Service.
- Merchandise description provided by the User in the Advertisement shall constitute the terms of such Merchandise sale.
- Delivery terms shall be included in the Merchandise description in the Advertisement.
- The terms of service provision or terms of sale and the merchandise description provided in the Advertisement, as well as other terms of the Advertisement shall not contradict the current legislation and this Agreement both at the moment of placing the Advertisement and later. If any term of the Advertisement is found to be in contradiction with the legislation or this Agreement as a result of entering amendments into the current legislation and/or the Agreement, such terms or such Advertisement shall be amended or modified by the User to eliminate any discrepancies. If it is impossible to make corresponding changes, the User shall eliminate such an Advertisement. In instances mentioned in this paragraph the Administration shall reserve the right to edit or remove such Advertisements without prior notification of the User.
- Advertisements about Merchandise and services contradicting the current legislation or generally accepted rules of morality, offensive and inappropriate, violating third party rights shall be prohibited from placement on the Web Service. The User shall make certain that the Merchandise offer does not contradict the current legislation and the terms of this Agreement. The list of merchandise and services prohibited from being published on the Web Service, set by the Rules of publishing Advertisements on the Web Service, is available in the How to Sell section at this address http://lalafo.gr/en/how-to-sell.
- Usage of paid services may not guarantee that the Advertisement shall not be blocked by the Administration in the event of violation of this Agreement. When the rules of placing Advertisements are violated, money paid for the services shall not be refunded.
- It shall be prohibited to include in the Advertisement references to the websites containing offers on how to sell, use or any other information about goods and services.
- The User shall not spread or provide assistance in spreading information about the services delivered by:
- other trading platforms, Internet auctions and/or Internet stores;
- other web services offering the same products and services as the ones displayed on the Web Service, for the same or lower price;
- other web services offering products and services prohibited from being sold on the Web Service.
- The User shall not use automatic programs to gain access to the Web Service without the Administration’s written permission. Usage of computer programs that allow placement of Advertisements bypassing the standard procedure of Advertisement placement shall be prohibited, unless there is the Administration’s written permission.
- While using or accessing the Web Service, the User shall not:
- infringe the copyright, trademark, patent, and/or other intellectual property rights that belong to the Web Service or other third parties, as well as shall not copy, reproduce, alter, distribute or make public any information available on the Web Service without the prior Administration’s written permission;
- breach or circumvent any laws, third-party rights or our systems, policies or determinations of the user`s account status;
- use the Web Service if he/she is not able to enter into legally binding contracts (for example, if the User is under 18 years old), or if the User’s access to the Web Service has been restricted or terminated;
- post false, inaccurate, misleading, deceptive, defamatory, or libellous content;
- transfer his/her account to another party without the Web Service’s consent;
- distribute or post spam, unsolicited or bulk electronic communications, chain letters, or pyramid schemes;
- distribute viruses or any other technologies that may harm the Web Service or the interests or property of users;
- use any robot, spider, scraper, data mining tools, data gathering and extraction tools, or other automated means to access the Web Service for any purpose, except with the prior consent of the Web Service;
- interfere with the working of the Web Service or impose an unreasonable or disproportionately large load on our infrastructure;
- collect information about Users without their consent.
- Information provided by the User and the User’s actions on the Web Service shall not:
- be false, inaccurate or deceiving;
- contribute to fraud, deceit or abuse of trust;
- lead to transactions involving stolen or counterfeit items;
- violate or encroach on the third party’s property, commercial secret, or privacy right;
- contain information harming someone’s reputation or business standing, or giving offence to someone;
- contain defamation or threat whomsoever;
- call to commit a crime, or ignite ethnic discord;
- give rise to, support or call to terrorist and extremist activities;
- be obscene or of pornographic nature;
- contain computer viruses, as well as other computer programs aiming, in particular, to cause harm, unauthorised intrusion, covert interception or acquisition of any system data or the system itself, or any of its parts, or personal information, or any other data (including the Web Service data);
- contain materials of advertising nature;
- violate third parties’ intellectual property rights, right for personal image protection, and other relevant third party rights;
- violate in any other way the applicable legislation.
- While using the Web Service services, the User shall have no right to place Advertisements on the Web Service, enter into or execute any transaction that can lead to violation of the applicable legislation by the Web Service and/or by the User.
- The Administration shall have the right to advertise Merchandise by placing an Advertisement thereof in a manner different from the one applied by the User while placing the Advertisement about such Merchandise.
- The Administration shall have the right to move, interrupt, end or prolong the duration of any Advertisement due to reasons dependent or independent on the Web Service.
- The Administration shall have the right to end Advertisement demonstration at any time due to the violation of the rules stipulated by this Agreement, as well as due to violation of other Users’ rights, or violation of the current legislation, or due to other reasons.
- The Administration shall have the right to edit Advertisements, move them to other sections, as well as perform other actions with the Users’ Advertisements.
- The Administration shall have the right to refuse placement (publishing) of Advertisements without giving reasons.
- Requirements for the design of Advertisement are provided in the Rules of publishing Advertisements on the Web Service in the How to Sell section at the address http://lalafo.gr/en/how-to-sell.
- The User shall bear full and exclusive liability for the Advertisement content in accordance with the current legislation. The Web Service accepts no responsibility and assumes no liability for any User content that the User or a third party posts or transmits using the Web Service.
3. Paid Services
- Users may order paid services on the Web Service.
- Types of paid services:
- VIP Advertisement
- Move my Advertisement to top х2
- Prices for the services and the procedure of ordering paid services are indicated in the corresponding pages of the Web Service.
- The Web Service User who has paid for the Web Service services shall have the right to request refund of the money from the Administration. The decision to issue or deny a refund shall be taken by the Administration unilaterally.
- Money paid for the services that have not been provided shall be refunded by the Administration in the following instances:
- The service failed to be provided due to technical reasons occurring on the Web Service.
- Other individual occasions at the discretion of the Administration.
- The Administration shall have the right to refuse a refund of the User’s funds in cases when:
- The User consistently violates the terms of this Agreement.
- The service has been activated, including cases when the Advertisement has been deleted after moderation.
- The User has placed an Advertisement about products, services and offers that are forbidden.
- Any deficiencies of the payment system. The Web Service shall bear no liability for the operation of the payment systems used by the Users to pay for the Web Service services. Refund of money in this case shall be considered on a case-by-case basis.
- Other cases at the discretion of the Administration.
- Refund procedure shall be decided on a case-by-case basis between the Administration and the User.
4. Communication and Notices
- The User’s correspondence with the Administration and the Web Service shall be performed via email email@example.com and/or the address, which is indicated in clause 1.2. of this User agreement. The User can access the Web Service for resolution of any query.
- The User shall be prohibited from placing comments, discussions or other messages on the Web Service regarding actions of the moderators and the Administration.
- The Web Service respects the intellectual property rights of others.
According to copyright laws, the Web Service shall respond to claims of copyright infringement on the Web Service.
A copyright owner or his/her authorized representative (the claimant) can report alleged copyright infringements on the Web Service by sending a Notice to the Web Service’s support.
The Web Service can take any action which may include removing the reported content from the Web Service.
If the relevant content is removed in response to a Notice, the Web Service may notify the person who posted it on Web Service so he/she have the opportunity to send a counter-notice. The Web Service may also send a complete copy of the Notice to others, if necessary.
The claimant bears full material, legal, and any other liability for the accuracy and reliability of the information specified in his/her Notice.
- The Administration is the exclusive owner of the domain name where the website is located, the website itself, its mobile applications, as well as all the Web Service and all the Web Service software.
- When installing the software, the Administration shall provide the User with the personal free non-exclusive license to use the software without the right of its assignment to third parties.
- Such license shall be designated solely to provide the User with the possibility to use the Web Service services and derive benefits from it, in accordance with the Web Service functions.
- It is forbidden to copy, alter, distribute, sell, exchange or lease completely or partially any part of (the Web Service) Administration’s intellectual property items (including its software), as well as to “crack” or try to retrieve the source code of the software without the Administration’s written permission.
- The User shall place certain information about himself/herself solely in his/her interests, including in order to facilitate communication with the User and/or identification of the User.
- By placing information about himself/herself, the User understands and agrees that such information is placed on the Web Service publicly, i.e. is available to any visitor or Users of the Web Service.
- The User understands and accepts all risks connected with such placement of information, including, but not limited to the risk of the email address getting to spammers’ address lists, risk of the email address getting into the hands of all kinds of fraudsters, risk of the telephone number getting to SMS-spammers and/or SMS-fraudsters, and any other risks caused by such placement of information.
- With regards to the Merchandise, the Web Service shall not serve as a dealmaker, mediator, buyer or seller.
- The Web Service shall bear no liability for the arrangement and performance (execution) of transactions between the Web Service Users, for any losses, lost profit or income, financial losses or indirect, actual, side or punitive losses as a consequence of entering into a transaction, as well as a result of unlawful actions of any person.
- By using services of the Web Service, the User shall agree to use the Web Service and its services at his/her own risk and shall carry all risks with regards to using Advertisements located on the Web Service.
- The Web Service is an instrument for the Users to place their Advertisements with regard to Merchandise the sale and/or purchase of which is allowed by law, this Agreement and other rules of the Web Service usage.
- The Web Service may not always verify Advertisements placed by the Users, and, as consequence, the quality, safety, legality and conformity of the Merchandise to its description, as well as the seller’s ability to sell, and the buyer’s ability to buy the Merchandise shall be out of the Web Service’s control.
- The Web Service may not exercise control over the reliability of the information placed by the Users in their Advertisements.
- The Web Service, its Administration, management and employees shall bear no liability whatsoever for the content or reliability of the Advertisements located on the Web Service.
- The Administration, its management and employees shall bear no liability whatsoever for the content of any messages (including those received by the Users in their inbox and/or on mobile phone), as well as for any usage of the Users’ contact information.
- The User agrees to indemnify and hold harmless the Web Service and its respective officers, directors, employees and agents from and against any claims, suits, proceedings, disputes, demands, liabilities, damages, losses, costs and expenses, including, without limitation, reasonable legal and accounting fees (including costs of defence of claims, suits or proceedings brought by third parties) that are in any way related to the User’s access to or use of the Web Service, the User’s content, or the User’s breach of any terms of this User agreement.
- The User understands that the fact of Advertisement placement on the Web Service shall not guarantee that offering, sale and/or acquisition of any Merchandise is valid and legal. The User shall be the sole decision taker in entering into a transaction.
- As long as the legislation permits, the total liability of the Web Service to cover any claims shall be restricted to the amount that has been paid by the User for using the Web Service services or (at the discretion of the Web Service) to the repeated provision of such services to the User.
- The User agrees that all disputes between the User and other users and/or the Web Service visitors (including those arising as a result of entering into transactions) shall be resolved by the User independently without involving the Administration.
- The Web Service shall bear no liability for any access of third parties to the Web Service services and/or any information about the Users (including their personal data), which has been gained without consent (authorisation) and/or awareness of the Administration.
- The User agrees that the Administration shall bear no liability and shall have neither direct, nor indirect obligations before the User in connection with any possible or actual losses and damage related to the Web Service content and/or as a result of the transactions performed by the User, copyright registration and information about such registration, product and services available on the Web Service or any other contacts the User has established using the information on the Web Service.
- The Administration shall carry no liability for any software failures, crashes and other technical and software disorders, as well as for the errors, software viruses, etc. that might be passed on to the Web Service or through the Web Service by the third parties.
- The User shall act exclusively in accordance with the current legislation and this Agreement, as well as bear full liability in accordance with the legislation for his/her actions or inaction on the Web Service and while utilising the Web Service services.
- If the User’s rights are violated by another Web Service User (unlawful use of an intellectual property item, etc.), the User whose rights have been violated shall have the right to address the Administration or its moderators with a complaint. The Administration shall review the complaint and, if found justified, shall take measures to stop violation of the User’s rights.
7. Duration of the Usage Rights
- This Agreement shall take effect from the moment when the User begins using the Web Service services, irrespective of the User’s registration or Advertisement placement, and shall remain in full force and effect indefinitely.
- The User shall have the right to terminate the right of using the Web Service services at any time. Once this is done, the User shall have no right to place new Advertisements.
- The Web Service shall reserve its right to stop, at its own discretion, the User’s access to the Web Service with or without cause or notice. The User whose access to the services has been terminated or whose data has ceased to be valid shall have neither the right to register again without obtaining a special permission of the Administration thereto, nor be able to use registration information of another User in order to gain access to the Web Service.
- Should any disputes arise, the Parties to this Agreement shall resolve them by means of negotiations. Disputes that arise while executing this Agreement and providing services by the Web Service shall be resolved in accordance with the current legislation.
- Resolution of all disputes shall be governed by the legislation of Estonian Republic.
- The Web Service shall reserve its right to amend this Agreement unilaterally and without notifying the Users. New edition of the Agreement shall take effect once it is published on the Web Service.
- Nothing in this Agreement shall be understood and interpreted as establishment of agency relationship between the User and the Administration, or relationship of association, cooperation, personal hire, or any other sort of relationship, unless expressly stipulated by this Agreement.
- If the Court holds any provision of this Agreement invalid or unenforceable, no other provisions of this Agreement shall be impacted by such Court decision.
- Inaction of the Administration when any of the Users violates provisions of this Agreement shall not deprive the Administration of the right to take appropriate measures in the future to protect its interests and rights.
- All other terms and circumstances, which are not stipulated by this Agreement, shall be decided on a case-by-case basis.
The User shall confirm that he/she has read all the provisions of this Agreement and accepts it fully and unconditionally.
Lalafo takes care of all its Users’ privacy. For this purpose, Lalafo collects and uses personal information only to the extent necessary to provide its Users with the services, websites, and mobile applications (collectively, “the Service”).
Personal data Controller shall be Private limited company Yalla Classifieds (YALLA CLASSIFIEDS OÜ), address: Pärnu Road 22, 10141 Tallinn, Estonia.
1. Data collection
- Personal data means information, which can be used to identify a natural person directly or indirectly. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data.
- The User shall provide information and personal data when filling out the form to publish Advertisement, or during registration to the Web Service, or when subscribing to receive messages, as well as in other cases of using the Web Service. Information may also be collected during surveys of the Web Service Users.
- The Web Service will collect the following information about Users:
- Personal information, which represents input by the User, shown or revealed in any other way by him/her to the Web Service when using the Web Service. Such information can include the User’s name and surname (company name), email address and password, phone number, location as well as address. The User needs to provide this information to enable the Web Service to provide User with the services and to provide access to the Web Service and the means for sellers and buyers to trade.
- Technical information, which is automatically collected by the Web Service when the Web Service is visited. The Web Service collects information from the device and from the application that Users use to access the services. Typically, this is information about User’s IP address, operating system version, device type, system and performance, and the type of browser. If the User accesses the Web Service from a mobile device, the Web Service also gets a universal unique identifier (UUID) for such device. The Web Service may combine this information obtained from the User’s browser or mobile device with other information about the User that the Web Service or its partners collect, including information collected from several devices.
- When the User logs in using another service profile (for example, Facebook, Google+, vkontakte, odnoklassniki.ru etc.), the Web Service may also collect information located in the relevant profile of such service that the User has agreed to make available, including the User’s name, email address, and profile-related information. The User agrees to share this data with the Web Service during the registration process. This permission can be revoked at any time by sending an appropriate request to the Service.
- The Web Service may collect information regarding the physical location of the User’s device. The individual User’s location may be determined through the IP or Geo-location information obtained from the User’s device. The Web Service can use and store the User’s location information to provide functions and improve and customize services, for example, for internal analytics and performance monitoring or for showing content or provide offers relevant to the User’s location.
- The Web Service uses “cookies” and similar technologies on its websites. More information about cookies is provided below in the “Cookies, Web Beacons, and Similar Technologies” section.
- The data provided by the User in connection with his/her participation in contests and surveys conducted by the Web Service or by other third parties at the request of the Web Service.
- The Web Service receives information about Users and their activities from marketers, partners, researchers, and other sources (including publicly available databases). The Web Service may combine information that is collected from the User with information obtained from other Users and third parties.
- The Web Service will not collect or process any “Special categories of data”, for example, the data about racial or ethnic origin, political, religious and ideological beliefs, membership in political parties and professional unions, criminal history, as well as data concerning health, sex life, biometrical or genetic data.
- Please note that any information posted by the User on the Web Service (e.g. User’s name and publicly available photos, etc.) will become public and may be available to other Users and the general public. The Web Service urges Users to be very careful when deciding what information to disclose through the Web Service. Personal information posted by Users or disclosed by them to other Users may be collected by other Users and may result in unsolicited messages. The Web Service is not responsible for protecting the information that the User may disclose to third parties through the Web Service.
- In order to facilitate interaction between the Users, the services shall imply restricted access to the contact information of other Users. The User Agreement shall restrict the right to use information provided by other Users.
2. Processing purposes
- Processing of the personal data is any action or combination of actions, such as collection, registration, accumulation, storage, adaptation, alteration, use, distribution (sale, transfer, including transfer abroad), and deletion of the personal data, including application of informational (automated) systems.
- The Web Service uses the personal information collected from Users for a range of different business purposes and according to different lawful bases of processing.
The Web Service may use the information collected from the Users as follows:
- To manage the Users’ accounts and provide them with user support. The Web Service uses Users’ information to resolve technical issues, to respond to Users’ requests for assistance, to analyse technical failure information, and to repair and improve the services.
- To develop, display, send, and track content and advertising adapted to the interests of Users in relation to the Web Service. The Web Service uses contact information and information about how Users use the Service to send notifications that may be of specific interest to the Users. These notifications are aimed at driving engagement and maximizing the benefits derived by the Users from the Web Service, including information about new features, newsletters, and events that may potentially be of interest to the Users. The Web Service also communicates with the Users about new product offers, promotions, and contests. The Web Service may communicate with the Users by e-mail, post, phone and/or mobile devices. The User can control these notifications and have the right to withdraw his/her consent at any time.
- To comply with legal, regulatory and law enforcement requests and protect the Web Service’s legitimate interests and rights. The Web Service cooperates with government and law enforcement officials and private parties to enforce the law. The Web Service shall disclose any information about the Users according to legal requirements where it is necessary to protect the Web Service’s legal rights and interests and/or legal rights and interests of third parties or to prevent or stop illegal activity.
The Web Service also uses information to restrict or prevent various forms of abuse of the services, such as fraud, spamming, and other unauthorized actions that violate the User agreement.
Where required by the law, the Web Service may use the information in connection with legal and audit activities, for example, for the purpose of acquisition, merger or sale of its business.
To the legally permitted extent, the Web Service will take reasonable steps to notify the Users about provision of personal information to third parties.
- Website analytics. The Web Service uses multiple web analytic tools (or tracking-tools) provided by third-party service providers such as Google Analytics to collect information about how Users interact with the Web Service. The Service conducts research and analysis of the User’s use of the Service or the interests of the User in products, services, and content. The Web Service uses the information provided by these tools to improve services and to detect and analyze errors. Such service providers’ tools place cookies in Users’ browsers. Cookies cannot be used by anyone other than third-party service providers. The information collected using cookies may be transmitted to and stored on servers in a country other than the User’s country. Information collected is used and shared by these service providers in accordance with their individual privacy policies. Users are free to opt-in to collection and processing of the data generated by the cookies in connection with the use of the Web Service.
- To conduct contests or surveys. The Web Service uses the information collected through these methods, for example, to improve the services.
- The Service shall not sell or lease information and/or personal data provided by the User in the process of using the Web Service.
3. Cookies, Web Beacons, and Similar Technologies
- Any information obtained by the Web Service from the User, as well as placement of cookies on the User’s browser shall be performed with notification and upon the User’s consent. By continuing the usage of the Web Service, the User shall give consent to the Web Service to store cookies on the User’s browser.
- Cookies is a term used in computer terminology to describe information in the form of a text or binary data received from the Web Service that is stored on the User’s side, i.e. on the browser, and is later sent to the Web Service when the User visits the Web Service again. In this way the Web Service marks the User’s browser during his/her visits to the Web Service. Cookies facilitate usage of the Web Service by recording the data necessary to log into the system and collect statistics. Cookies do not contain personal data.
- Web beacons are small graphic images (also known as “point markers” or “Network beacons”) that may be turned on in the Web Service, as well as its servers, applications, exchange of messages, and in the tools, which usually function in combination with cookies in order to identify the User.
- Similar technologies are technologies that store information in the browser or the device using local general objects or a local storage, such as “flash cookies”, “HTML 5 cookies”, and other methods of web-applications. Such technologies may work in all browsers of the User, and in some cases they may not be fully controlled by the browser and may require direct control through the applications or devices installed by the User.
- Third party services are provided by companies that help to operate the Web Service. The Only authorised service providers are used to deliver Web Service to the User, as well as for other purposes directly related to the Web Service operation. Such service providers may also place cookies on the User’s device. They may also collect other information, for instance IP address or other identifiers.
- The User shall have the right to block, delete or turn off such cookies and similar technologies, as long as the User’s device allows doing so.
- The User can manage cookies in the browser. In order to reject collection and storage of information, the User shall check “Do not store cookies” in the browser settings, as well as press the button “Clear cookies”. Cookies may be removed from the User’s devices at any time. The preferences for each browser User uses will need to be set separately and different browsers offer different functionality and options. For more information on how User can block, delete, or disable these technologies, please review browser or device settings.
- However, if the User declines cookies or other similar technologies, the User may not be able to take advantage of certain site features, services, applications, or tools. The User may also be required to re-enter password more frequently during browsing session.
4. Sharing and disclosure of information
- The Web Service may share and disclose the User’s information to third-party service providers that provide services to the Web Service, namely, website hosting, data analysis, information technology and related infrastructure provision, email and messages (notifications) delivery, auditing, services that assist the Web Service in providing customised advertising and service providers for the management of service desk, support data and CRM systems. These Services help the Web Service to provide services (for example, they can assist the Web Service in providing customised advertising or they can assist the Web Service with the prevention, detection, mitigation, and investigation of potentially illegal acts). These service providers will only have access to the information necessary to perform the relevant functions. These third parties are obligated not to disclose or use User’s information for other purposes. In some cases, these service providers are not strictly required to provide the services for the Web Service, but they help to make the Web Service better. Cooperation with third-party service providers with the aim to make the services better is the Web Service’s legitimate interest (to ensure the adequate performance of the contract with the User).
The Web Service also uses the online advertisement services to display advertisement Google Adsense and DoubleClick for Publishers. The User can find more information on the privacy practices of Google here: https://policies.google.com/privacy?hl=en
- The Web Service may transfer portions of the Users’ information outside of the User`s country of residence. For example, personal data stores on servers located in Germany. The Web Service has established legal mechanisms to ensure that Users’ rights are protected irrespective of such transfers.
If personal data is transferred to a third country (i.e. a country outside the Europe Union or the European Economic Area), the transmission of data will be governed by the principles of the Privacy Shield (https://www.privacyshield.gov/welcome) or will be performed on the basis of the standard contractual clauses established by the European Commission (http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm and https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en).
- The Web Service may share the Users’ information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside the User’s country of residence, to comply with legal, regulatory, and law enforcement requests and protect the Web Service’s legitimate interests and rights.
For example, the Web Service may disclose the User`s personal data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of The Web Service
- To prevent or investigate possible wrongdoing in connection with the Web Service
- To protect the personal safety of users of the Web Service or the public
- To protect against legal liability
Nevertheless, if necessary, the Web Service may ask for User`s consent to share/disclose his/her information. In any such case, the Web Service will provide a full explanation why and what information the Web Service needs to share/disclose.
5. Data protection
The Controller shall take all reasonable technical and organisational measures to protect personal data of the User from unauthorised access by third parties.
The Web Service conducts review of candidates at the time of hire or before entering into a contract with independent contractors (to the extent permitted or facilitated by applicable laws and countries). Also, signed non-disclosure agreements. The Web Service provides ongoing privacy and security training.
All personal data collected and processed by the Web Service shall be stored on one of the several protected servers. There shall be no access to such servers outside the corporate network or contractors that signed the Non-disclose agreement.
Nevertheless, while the Web Service implements safeguards designed to protect the Users’ information, no security system is impenetrable and the Web Service cannot guarantee that data, during transmission through the Internet or while stored on servers or systems owned by the Service, will be absolutely safe from intrusion by third parties.
6. User’s legal rights
The Web Service will honour any statutory right the User might have to access, modify or erase his/her personal information.
Every User has account settings that help him/her access, rectify or delete information that the User provides to the Service. User can change his/her settings on their devices to either consent or oppose the collection of the personal information or display of the corresponding notifications.
Mobile applications have permission systems for specific types of device data and notifications such as location as well as push notifications. Please note that certain services may lose full functionality because of deactivation of certain functions.
User can contact the support of the Service (firstname.lastname@example.org) with any questions regarding these settings.
According to applicable laws, the Users have the following rights (inter alia):
- to request access to the User`s personal data. This enables the User to receive a copy of the User`s personal data stores by the Web Service and to check that the Web Service is lawfully processing it.
- to request correction of the User`s personal data. This means the User can correct any incomplete or inaccurate data. Please note that the Service may need to verify the accuracy of the new data.
- to request erasure of the User`s personal data. The User can ask the Web Service to delete or remove personal data where there is no good reason for the Web Service continuing to process it. The User also have the right to ask the Web Service to delete or remove the User`s personal data, where the Web Service may have processed personal data unlawfully or where the Web Service is required to erase personal data to comply with local law.
- to object to the processing of the User`s personal data (for example, when the personal data is processing for direct marketing purposes). In some cases, the Web Service may demonstrate that the Web Service has compelling legitimate grounds to process information which override the User`s rights and freedoms.
- to request restriction of processing of the User`s personal data. The User have the right to obtain from the Web Service restriction of processing where one of the following applies:
(a) the accuracy of the personal data is contested by the User, for a period enabling the Web Service to verify the accuracy of the personal data;
(b) the processing is unlawful and the User opposes the erasure of the personal data and requests the restriction of their use instead;
(c) the Web Service no longer needs the personal data for the purposes of the processing, but they are required by the User for the establishment, exercise or defence of legal claims;
(d) the User has objected to processing pending the verification whether the legitimate grounds of the Web Service override those of the User.
- to request the transfer of the User`s personal data to the User or to a third party. The Web Service will provide to the User, or to a third party the User`s personal data in a commonly used machine-readable format.
- to withdraw consent at any time where the Web Service is relying on consent to process the User`s personal data. However, this will not affect the lawfulness of any processing carried out before the User withdraw his/her consent. If the User withdraws his/her consent, the Web Service may not be able to provide certain products or services to the User.
Please note that the Service may reject requests for certain reasons, including if the request is unlawful or if it may violate the rights of another User or a third party.
In certain countries, the Users have the right to lodge complaints with the appropriate data protection authorities if they have concerns about how their personal data are processed.
7. Messages and Notifications
Occasionally, the Web Service may need to contact the User. These messages can be delivered by email, by push notifications or by telephone for the purposes of provision of the Users with support or for other purposes (for example, provide the Users with information regarding products and features that Users may find interesting). These notifications could be sent with prior consent of the User or in response to the Users’ requests. The User may control marketing emails and/or messages through his/her account settings as well as through the opt-out link included in the marketing emails or messages.
If the User give his/her consent to receive notifications, he/her confirms that the Web Service shall have the right to provide User`s email addresses and phone numbers to third parties in order to deliver notifications and messages to the User.
Some messages may be published on the Web Service (for example, messages from other Users with propositions to buy/sell or certain Web Service’s messages). Advertisements published on the Web Service shall be deemed delivered to the User once they are published.
Some messages are service-related and necessary to provide services by the Web Service and/or performance of the User agreement (non-marketing messages, for example, emails related to the Users’ accounts, security-related notifications, etc.). The User agrees that such messages can be sent to him/her.
The Web Service shall bear no liability for the use of the message sending form placed on the Web Service by other Users and/or automated systems (robots).
The Web Service shall bear no liability for the use of the phone numbers and electronic addresses placed by the User on the Service pages by other Users and/or robots.
8. Access to and deletion of the User`s information
The User can exercise his/her rights to access, change or delete his/her personal information at any time.
In order to easily access, view or update personal data (where available) or to update subscription preferences, the User should enter his/her account and visit the “Account Settings” section.
Please note that the Web Service will not be able to provide access to the services if the User revokes his/her consent. Also, the Service will not be able to provide certain services if the User deletes his/her account/data.
In order to ensure the Users’ protection, support managers of the Web Service may only respond to requests for personal information sent from the email addresses the Users use to send requests, and the Web Service may need to verify the relevant User`s identity before implementing his/her request. The Web Service will try to comply with the User`s request as soon as possible, but it may require some time.
9. Data retention
The Web Service keeps the Users’ information only as long as needed for legitimate business purposes and as permitted by applicable legal requirements.
Personal data is deleted or anonymized on a regular basis when it is no longer relevant for the purposes, for which it has been collected.
10. Final provisions
- The User shall bear liability for the accuracy and reliability of any information and data provided by him/her.
- The services are not designed for individuals under the age of eighteen (18). The Web Service will not knowingly collect personal information from children under 18 if they use the Web Service.
- If the User has any questions or complaints, he/she may contact the support by email: email@example.com
or by sending a letter to the following address:
Pärnu Road 22, 10141 Tallinn, Estonia.