1. SCOPE AND CONSENT COLLECTION

1.1. Personal data of users of pmclub.ua/ are processed on protected servers, located in Ukraine.

1.2. The present Privacy Policy sets out the personal data processing procedure, relating to the personal data collected via the Website (hereinafter – “Website”), the mobile application pmclub.ua/ (hereinafter – “mobile app”) and services and instruments related thereto, that allow the users to register on the Website and use the other service, pmclub.ua/, related to the Website. In all the above cases the Company processes the personal data of the users in strict compliance with the Law of Ukraine “On personal data protection” and the Convention on automated processing of personal data. This Privacy Policy has been developed in accordance with the provisions of the said legislation.

1.3. By using the website and/or the mobile app and/or other related services and instruments pmclub.ua/, the User consents to the processing of his/her personal data, such as: surname, name, patronymic; area of residence, e-mail address, phone number, gender, date of birth, other contact data optionally provided by the User; IP-addresses, other communication data of the User; messages, letters, notifications that are sent to the User by other users and vice versa; the User also consents to the transfer of his/her personal data to third parties, including to the transfer of such data abroad, to any third country, in accordance with the provisions of this Privacy Policy.

1.4. The Users should be aware that when following certain links on the Website or in the mobile app they might be redirected to websites (with applications etc.) of other companies outside the hosting area of pmclub.ua/, where the information on Users is collected without direct control of pmclub.ua/. In such cases the privacy policies of websites and/or applications of third parties shall apply to the processing of the information received by such third parties from the Users.

2. INFORMATION THAT IS COLLECTED, RECEIVED AND DISCLOSED BY THE COMPANY

2.1. Log data: when the User creates an account on the Website, pmclub.ua/ may request certain information, such as a valid e-mail address and password. The account includes the following information about the User: his/her geographical location, surname, name, patronymic, phone number and related information, including photos, that may be uploaded by the Users to their accounts. {The accounts allow Users to connect with one another to express their interest in the offers }. The Users are responsible for any and all information provided by them in open accounts. The User has to be aware of all risks related to publishing his/her address or information about his/her location. Should the User decide to enter the Website via the authentication service of another operator, e.g. social login via Facebook etc., the Company may obtain the additional profile or other information, the access to which was provided by such third party.

2.2. Announcement and Agreements: As part of the Website operation, pmclub.ua/ may disclose information, including personal data and contact data, that is necessary to enter into agreements, sending notifications and communication between the users, effecting payments. All information needed to publish announcements is needed to create an account. The Users are responsible for all the information disclosed by them on the Website. The User has to be aware of all risks related to publishing his/her address or personal information.

2.3. Games, Advertising and Promotion: As part of the Website operation, pmclub.ua/ may collect personal data, such as surname, name, patronymic, contact data, information on the Users’ participation in games, trivia and other marketing events organized on the Website or third-party websites. As part of the Website operation, pmclub.ua/ may process data related to the effectiveness of advertising campaigns, including data on ads view on the Website and third-party websites.

2.4. Customer service: When the Users address the customer service department, pmclub.ua/ may, if necessary, as part of the Website operation collect data necessary to respond to the Users’ requests and receiving feedback. Рmclub.ua/ may contacts the Users using the existing contact data of the account that was provided for this purpose. Рmclub.ua/ may also collect other data on Users’ communication, e.g. requests filed by the User to the customer service or any other feedback provided by the Users, including in the form of Users’ reviews. We may process the reviews as data related to the User – author of the review, as well as to the User, whom such review concerns.

2.5. Website and mobile data: pmclub.ua/ may automatically obtain and register on its server data from the User’s browser or any other device, including the IP-address, User’s geolocation, software and hardware attributes, pages prompted by the User, data contained in the browser data bases, including SQL data bases, mobiles IDs (including such mobile identifiers as Google Advertisement ID, IFA or IFV), information on the use of applications and/or information on other devices used, or system-level information. This may take place on the Website or in the mobile app, or on the third-party servers. Additional information on how the Users may control and/or block such collection of information is given below in Section 6 of the present Privacy Policy.

2.6. Information obtain via surveys: pmclub.ua/ may collect and store information obtained via surveys, that can be held by pmclub.ua/ or by subcontractors – third parties, engaged by pmclub.ua/, including but not limited to information on the gender, age, marital status, personal preferences etc.

2.7. Additional information: pmclub.ua/ may also add to the existing personal data of the pmclub.ua/ Users the information, that is lawfully obtained from business partners or third parties.

2.8. Information accessible through Users’ profiles on multi-user internet platforms (social media): When registering on the Website or entering the Website via social login, the User grantspmclub.ua/ consent to collection and processing of personal data that is accessible on the respective profiles in social medial, as well as to the publishing in such social media of information on the activities of the Use on the Website and/or mobile app.

2.9. Information on ratings and evaluations: we process information from your evaluations and reviews, that you have received from other Users. We process this information in order to estimate the satisfaction level of the Users and ensure the best possible communication level between the Users, to identify unwanted activities, and to be able to take respective actions to maintain a high level of operational standards of the Service.

2.10. Information that is not collected and not processed by pmclub.ua/

2.11. Рmclub.ua/ does not collect and does not process personal data on race or ethnic origin, political, religious or other preferences, membership in political parties or trade unions, or any other information of like kind.

IP-ADDRESSES, COOKIES AND MOBILE IDs

3.1. As part of the operation of the Website, pmclub.ua/ may collect certain information via cookies, pixels and local web storage (both in your browser and mobile device).

3.2. COOKIES are small pieces of data stored on the User’s computed, mobile phone or other device

3.3. Tracking pixels are small pixel graphics that are part of the HTML code and allow the other server to track web traffic, and are often used in combination with the cookies. The code tracks how, when (and on which website) the pixel was downloaded to show the interaction of the user with the website or part of the website.

3.4. With the help of the cookies the web-server can store e.g. User preferences and settings on the User’s computer, mobile phone or other devise, which preferences and settings are later automatically restored when the User visits the website the next time. In other words, cookies are used in order to make the use of the Website more convenient, e.g. so that the User does not need to log into the system each time he/she visits the Website. The Company uses both persistent and session cookies. A persistent cookie is stored on the User’s computer during a longer period of time, and a session cookie is automatically deleted when the browser window is closed.

3.5. The Company may grant certain third parties (such as advertisement suppliers and/or analytical services suppliers) the right to collect information with the use of the above technologies vie its Website or mobile app. The data collected by such third parties is protected by their privacy policies.

3.6. The User independently decides whether to save the password for entering the personal page using the above means. In case of loss of the password or illegal acquisition of information about the password to the User's personal page, the Company is not responsible for the storage of such data, their loss and possible negative consequences.

4. USE OF PERSONAL DATA

4.1. For purposes of providing its services, pmclub.ua/ may use the information that pmclub.ua/ collects and discloses for the following purposes:

4.1.1. ensuring customer services, including for purposes of creating and maintaining Users’ accounts, dealing with technical issues and accessing various functions;

4.1.2. adapting the offers and experiences, including its advertising in its services or third-party services;

4.1.3. control of the general and individual activity of Users, e.g. keyword research, ad effectiveness tracking, agreements conclusion tracker, traffic control on the Website;

4.1.4. communication with the Users, including on issues relating to the service, customer care and allowed marketing communications via any available communication channels;

4.1.5. conducting scientific, research and analytical activity for purposes of improving the service; and

4.1.6. ensuring the compliance with the Agreement with the Users of the pmclub.ua/ services, including for purposes of combating fraud and online bullying;

4.1.7. evaluating certain factors of personal data, such as analyzing and predicting individual preferences, interests, actions and location.

4.2. Рmclub.ua/ shall store your personal data for such a period of time, that is necessary to achieve the purposes for which such personal data has been collected, including for purposes of complying with any legal, accounting or reporting requirements. In order to determine the respective storage period, pmclub.ua/ shall take into account the scope, nature and sensitivity of personal data, potential risks of damages from unauthorized use and disclosure of your personal data, purpose, for which pmclub.ua/ is processing your personal data, as well as the ability of pmclub.ua/ to achieve these purposes by other means, and respective legal requirements.

5. EXCHANGE OF INFORMATION

5.1. Рmclub.ua/ may exchange the collected information with affiliated companies in any country. Such companies may only process and use the personal data for purposes indicated in Section 4 of the present Privacy Policy. However, even after its transmission such personal data remains subject to the present Privacy Policy.

5.2. Рmclub.ua/ shall not provide personal data to non-affiliated persons, unless explicitly allowed by the User or in the following cases:

5.3. Рmclub.ua/ may engage third-party service providers in order to provide certain components of its services, and in such cases the service providers will be entitled to use the personal data obtained via the Website for purposes other than providing the services by pmclub.ua/, yet such personal data will remain protected by this Privacy Policy.

5.4. Рmclub.ua/ reserves the right to exchange information with private persons and government authorities in accordance with the current legislation for the following purposes: • combating fraud and abusive practices on the Website; • investigating alleged violations of the law.

5.5. Рmclub.ua/ may provide User’s personal data to competent authorities upon motivated requests, that are drawn up in compliance with legislative procedures, including such under Art. 93 of the Criminal Procedure Code of Ukraine.

5.6. In accordance with the Privacy Policy, pmclub.ua/ undertakes not to rent or sell any User’s personal data. Should the business pmclub.ua/ or part thereof be sold or restructured, and should pmclub.ua/ transfer all or almost all of its assets to the new owner, the User’s personal data may be transferred to the buyer in order to ensure the continuity of the Website maintenance.

5.7. Рmclub.ua/ may transfer certain depersonalized information (data, that does not allow to identify a certain user) to third-party service providers, trusted partners or authorized researchers in order to ensure better understanding of which advertisement and services may be of interest for the Users, to increase the general level of service quality and effectiveness of the services provided via the Website or through the services, as well as to contribute to scientific researches that, according to pmclub.ua/, may be of substantial value to the society.

5.8. Рmclub.ua/ may transfer information that it collects to third parties, that provide services to the Company, for research purposes or for purposes of provision of services to the Company, yet any personal data transferred in such a manner shall remain protected by this Privacy Policy, and any engaged third parties shall not be entitled to use the received information for no other purposes than the provisions of services to pmclub.ua/.

5.9. In case of transfer of personal data under this Section 5 of the Privacy Policy, it is under the discretion of pmclub.ua/ to inform the User of such transfer.

6. USER CONTROL

6.1. Access, Correction and Withdrawal: The Users, who have created an account or have placed an advertisement on the Website, may have access, correct or withdraw information provided by them. The User is responsible for the accuracy of data and advertisements on the Website. In case the User account has been created via social login (e.g. Facebook), the User may also disconnect or change the account data via the social login settings (e.g. at facebook.com). The information provided may be altered or withdrawn in the personal account of the User via “My Profile” in the Website or in the mobile app. Рmclub.ua/ may terminate the processing of the User’s personal data upon a written notification of the User by which notification the User withdraws its consent to personal data processing.

6.2. Choice of third parties: certain third parties that operate on the Website, e.g. Google Adwords, allow users to withdraw their consent to collection and use of personal data for advertising purposes based on the user’s activity. For more information and setting please visit http://www.networkadvertising.org.

6.3. Cookies: Most of the computer (desktop) and mobile web-browsers (e.g., Safari, Firefox, Internet Explorer, Chrome, Opera) use control components that allow users to restrict or block cookies in your systems. Please mind, that by disabling Cookies for first-party domains (visited websites) and third-party domains (related websites) may in some cases lead to a limited functionality of such websites.

6.4. Other rights of the Users relating to the processing of their personal data:

6.4.1. know about the location of the personal data database, that contains personal data of the pmclub.ua/ Users, its purpose and name, location of the owner and personal data operator, or commission the authorized users of the Website to obtain such information, unless otherwise provided by the current legislation;

6.4.2. obtain information on the conditions personal data access, including information about third parties to whom personal data of the Website’s Users is transferred;

6.4.3. access to their personal data;

6.4.4. no later than within 30 days after a respective written request, unless otherwise provided for by the current legislation, information on whether the User’s personal data is processed or stored, as well as obtain information on the scope of such personal data;

6.4.5. address a reasoned request to the owner of personal data regarding the objection to personal data processing;

6.4.6. address a reasoned request regarding the change or destruction of personal data by the owner and/or operator of personal data, in case such personal data is illegally processed or is invalid;

6.4.7. personal data protection against unlawful processing, loss, destruction, alteration due to deliberate withholding, failure to provide access or provide late access, as well as against misinformation or provisions of information that damages one’s honor dignity and business reputation;

6.4.8. address a complaint to governmental authorities and officials, that are authorized to handle personal data protection issues, as well as to the courts against personal data processing;

6.4.9. use any legal remedies available in case of any violation of the laws on personal data protection;

6.4.10. withdraw the consent to personal data processing;

6.4.11. be informed about the means of automated processing of personal data;

6.4.12. be protected against an automated decision that might have legal consequences for the Website Users.

7. SECURITY

7.1. Any and all information reasonably collected by us is protected by technical means and security procedures in order to prevent unauthorized access to or use of personal data. The Company’s affiliated persons, trusted partners and independent service providers undertake to use the information, obtained from pmclub.ua/, in strict compliance with our security requirements and the present Privacy Policy.

7.2. Should pmclub.ua/ introduce any changes to the Privacy Policy, with which changes the User does not agree, the User shall terminate the use of the Website services. Should the User continue to use the Website, such use shall be deemed consent of the User to and acceptance by the User of the respective updated version of the Privacy Policy.