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Privacy Policy

1. General Provisions

1.1. This Privacy Policy (hereinafter referred to as the "Policy") defines the procedure for collecting, using, storing, and protecting personal data of users (hereinafter referred to as "Users") of the SpringSPM system (hereinafter referred to as the "System"), which provides services for automating commission calculations and displaying relevant analytics.

1.2. The purpose of this Policy is to ensure proper protection of personal data processed in the System, in accordance with the legislation of Ukraine on personal data protection.

1.3. By using the System, the User agrees to the terms of this Policy and provides consent for the collection, processing, and storage of their personal data.

1.4. If the User does not agree with the terms of this Policy, they must cease using the System.

2. Collection and Use of Personal Data

2.1. Categories of Data Collected:

  • Identification Data: Name, surname, patronymic, position.
  • Contact Data: Phone number, email address.
  • Professional Data: Information about completed sales, achieved targets, commission rewards.
  • Technical Data: IP address, browser type, access time, cookies.

2.2. Purpose of Data Collection and Processing:

  • Providing access to the functionality of the System.
  • Automating commission calculations.
  • Displaying personalized analytics, graphs, and widgets.
  • Supporting and improving the performance of the System.
  • Interacting with the User, including responses to inquiries and notifications about updates.

2.3. Legal Grounds for Data Processing:

  • Consent of the User for the processing of personal data.
  • Performance of a contract between the User and the System.
  • Compliance with legal obligations.

3. Protection and Storage of Data

3.1. Methods of Data Protection:

  • Use of encryption for transmitting and storing confidential data.
  • Restricting access to personal data to authorized personnel only.
  • Regular software updates and application of antivirus protection.
  • Conducting security audits and penetration testing.

3.2. Data Retention Period:

Personal data is stored for the period necessary to achieve the purposes of their processing but not longer than stipulated by law.

3.3. Data Destruction:

Upon expiration of the retention period or at the User's request, personal data is destroyed or anonymized in such a way that the identification of the User becomes impossible.

4. Transfer of Data to Third Parties

4.1. Conditions for Data Transfer:

Personal data may be transferred to third parties only with the User's consent or in cases provided by the laws of Ukraine.

4.2. Third-Party Services:

The System may use third-party services for data processing (e.g., cloud storage, analytical platforms) that ensure a level of data protection not lower than established by this Policy.

4.3. International Data Transfer:

In the event of transferring personal data outside of Ukraine, the System ensures compliance with all legal requirements regarding such transfer.

5. User Rights

5.1. Right of Access:

The User has the right to obtain confirmation as to whether or not personal data concerning them is being processed and, if so, access to the personal data.

5.2. Right to Rectification:

The User may request the correction of inaccurate or incomplete personal data.

5.3. Right to Erasure ("Right to be Forgotten"):

In certain circumstances, the User has the right to request the deletion of their personal data.

5.4. Right to Restrict Processing:

The User may request the restriction of processing their data under specific conditions.

5.5. Right to Data Portability:

The User has the right to receive their personal data in a structured, commonly used, and machine-readable format.

5.6. Right to Object:

The User may object to the processing of their personal data for certain reasons.

5.7. Right to Withdraw Consent:

If the processing of data is based on consent, the User may withdraw their consent at any time.

6. Cookies and Other Tracking Technologies

6.1. Use of Cookies:

The System uses cookies to collect information about the User's interaction with the System to improve its performance.

6.2. Types of Cookies:

  • Session Cookies: Temporary files that are deleted after closing the browser.
  • Persistent Cookies: Stored on the User's device until they are deleted.
  • Analytical Cookies: Used to collect statistical data.

6.3. Managing Cookies:

The User can configure their browser to refuse cookies or to notify when cookies are being used. However, this may affect the functionality of the System.

7. Data Security

7.1. Technical and Organizational Measures:

  • The System employs SSL/TLS protocols for data encryption.
  • Regular backups are performed to prevent data loss.
  • Access management policies are in place to limit access rights to data.

7.2. Security Breach Notifications:

In the event of a personal data security breach, the System will notify the User and relevant authorities in accordance with legal requirements.

8. Interaction with Other Websites and Services

8.1. Links to Third-Party Resources:

The System may contain links to other websites that have their own privacy policies. The System is not responsible for the content and practices of such websites.

8.2. Integration with Third-Party Services:

The System may integrate with third-party services (e.g., payment systems, CRM) that may collect additional data. The use of such services is governed by their respective privacy policies.

9. Children's Privacy

9.1. Processing of Children's Data:

The System is not intended for use by individuals under the age of 16. We do not knowingly collect personal data from children without parental or legal guardian consent.

10. Changes to the Privacy Policy

10.1. Policy Updates:

The System may periodically update this Policy. Changes will become effective upon their publication on the System's website.

10.2. Notification of Changes:

In the case of significant changes, the User will be notified via email or through a notification within the System.

11. Contact Information

11.1. Contacting the Administration:

For questions related to this Policy or the processing of personal data, the User can contact us at: springspm.info@gmail.com.

11.2. Complaints and Requests:

If the User believes that their rights have been violated, they have the right to file a complaint with the appropriate governmental authority or seek legal remedy.

12. Final Provisions

12.1. Disclaimer:

The System is not responsible for any damage or loss resulting from unauthorized access to personal data if such breaches occur without the fault of the System.

12.2. Governing Law:

This Policy is governed and interpreted in accordance with the laws of Ukraine.

12.3. Language of the Policy:

This Policy is drafted in Ukrainian. In the event of any inconsistency between the Ukrainian version and a translation, the Ukrainian version shall prevail.

13. Agreement with the Policy

13.1. Acceptance of Terms:

By using the System, the User confirms that they have read and agree to the terms of this Policy.

13.2. Refusal to Use:

If the User does not agree with any provision of this Policy, they must discontinue using the System.

14. Processing of Special Categories of Data

14.1. Confidential Data:

The System may process data regarding the User's financial indicators, which are considered confidential. Such data is encrypted and access is restricted.

14.2. Data Anonymization:

Where possible, the System anonymizes data to minimize risks to the User.

15. Automated Decision-Making

15.1. Profiling:

The System may perform automated data processing for analyzing and forecasting the User's performance indicators.

15.2. User Rights:

The User has the right not to be subject to a decision based solely on automated processing if such decision has legal effects or significantly affects them.

16. User Obligations

16.1. Providing Accurate Data:

The User agrees to provide accurate and up-to-date personal data.

16.2. Maintaining Confidentiality of Account Data:

The User is responsible for maintaining the security of their account and password.

17. Questions and Suggestions

17.1. Feedback:

We are always open to your questions and suggestions for improving our Policy and the operation of the System.