Privacy Policy for Personal Data

This Privacy Policy for personal data (hereinafter referred to as the “Privacy Policy”) applies to all information that the copyright holder of the “b.smart” application, located at: 61064, Kharkiv, Kombainivska St., 37, may obtain about the User while using this application.

1. DEFINITIONS

1.1 The following terms are used in this Privacy Policy:

1.1.1. “Copyright Holder of the ‘b.smart’ application” (hereinafter referred to as the “Copyright Holder”) – authorized personnel acting on behalf of the Copyright Holder who organize and perform the processing of personal data, and determine the purposes of processing personal data, the composition of personal data to be processed, and the actions or operations performed with personal data.

1.1.2. “Personal Data” – any information related directly or indirectly to an identified or identifiable individual (subject of personal data).

1.1.3. “Processing of Personal Data” – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

1.1.4. “Confidentiality of Personal Data” – a mandatory requirement for the Copyright Holder or any other person who has gained access to personal data not to disclose such data without the consent of the data subject or other legal grounds.

1.1.5. “User of the ‘b.smart’ application” – a person using the “b.smart” application.

2. GENERAL PROVISIONS

2.1. Use of the “b.smart” application by the User signifies acceptance of this Privacy Policy and the terms of processing the User’s personal data.

2.2. If the User disagrees with the terms of the Privacy Policy, they must stop using the “b.smart” application.

2.3. This Privacy Policy applies only to the “b.smart” application.

2.4. The Copyright Holder does not verify the accuracy of the personal data provided by the User.

3. SUBJECT OF THE PRIVACY POLICY

3.1. This Privacy Policy establishes the obligations of the Copyright Holder regarding the non-disclosure and protection of the confidentiality of personal data provided by the User upon request when installing the “b.smart” application on their mobile device.

3.2. Personal data permitted for processing under this Privacy Policy are provided by the User by filling out a registration form during initial registration as a user of the “b.smart” application and include the following:

3.2.1. Device data (IMEI/Android ID), approximate location (if permission is granted).

3.3.2. The Copyright Holder collects statistics about the date and time of user login/logout to/from the “b.smart” application. This information is used to identify and resolve technical issues.

3.4. Any other personal information not specified above (used browsers and operating systems, etc.) is securely stored and not disclosed, except as provided in paragraphs 5.2. and 5.3. of this Privacy Policy.

4. PURPOSES OF COLLECTING USER’S PERSONAL INFORMATION

4.1. The Copyright Holder may use the User’s personal data for the following purposes:

4.1.1. Identifying the User.

4.1.2. Providing the User with access to personalized resources of the “b.smart” application.

4.1.3. Receiving a unique identifier (IMEI) from the device, displaying the device on the server as “unregistered,” and enabling its subsequent registration by an operator in the system with a custom name.

4.1.4. Displaying the registered device on the map and determining its approximate location to provide the user with information about the device’s current location.

4.1.5. Verifying the accuracy and completeness of personal data provided by the User.

4.1.6. Providing the User with effective customer and technical support in case of issues related to the use of the “b.smart” application.

4.1.7. Providing the User, with their consent, updates for the “b.smart” application.

5. METHODS AND TERMS OF PERSONAL DATA PROCESSING

5.1. The User’s personal data is processed without limitation of the term, in any legal manner, including in personal data information systems using automation tools or without the use of such tools.

5.2. The User’s personal data may be transferred to authorized state authorities of Ukraine only on the grounds and in the manner established by the legislation of Ukraine.

5.3. In case of loss or disclosure of personal data, the Copyright Holder informs the User of the loss or disclosure.

5.4. The Copyright Holder takes necessary organizational and technical measures to protect the User’s personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as other unlawful actions of third parties.

5.5. The Copyright Holder, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data.

6. OBLIGATIONS OF THE PARTIES

6.1. The User shall:

6.1.1. Provide information about personal data required to use the “b.smart” application.

6.1.2. Update or supplement the provided personal data in case of changes.

6.2. The Copyright Holder shall:

6.2.1. Use the received information exclusively for the purposes specified in Section 4 of this Privacy Policy.

6.2.2. Ensure confidential storage of information and not disclose it without the prior written consent of the User, nor sell, exchange, publish, or otherwise disclose the User’s personal data, except as specified in paragraph 5.2. of this Privacy Policy.

6.2.3. Take precautions to protect the confidentiality of the User’s personal data in accordance with commonly accepted practices.

6.2.4. Block personal data related to the relevant User from the moment of a request from the User or their legal representative or an authorized body for the protection of personal data subjects’ rights during the verification period, if inaccurate personal data or unlawful actions are detected.

7. LIABILITY OF THE PARTIES

7.1. The Copyright Holder who has failed to fulfill its obligations is liable for damages incurred by the User due to the unlawful use of personal data, in accordance with the legislation of Ukraine, except as provided in paragraphs 5.2. and 7.2. of this Privacy Policy.

7.2. In the event of loss or disclosure of Confidential Information, the Copyright Holder shall not be liable if the confidential information:

7.2.1. Became public before its loss or disclosure.

7.2.2. Was received from a third party prior to its receipt by the Copyright Holder.

7.2.3. Was disclosed with the User’s consent.

8. DISPUTE RESOLUTION

8.1. Before filing a lawsuit over disputes arising from the relationship between the User and the Copyright Holder, it is mandatory to submit a claim (a written proposal for voluntary settlement of the dispute).

8.2. The recipient of the claim shall notify the claimant in writing of the results of the review of the claim within 30 calendar days from the date of receipt.

8.3. If an agreement is not reached, the dispute shall be referred to the court in accordance with the current legislation of Ukraine.

8.4. This Privacy Policy and the relationship between the User and the Copyright Holder are governed by the current legislation of Ukraine.

9. ADDITIONAL TERMS

9.1. The Copyright Holder has the right to make changes to this Privacy Policy without the User’s consent.

9.2. The new Privacy Policy comes into force from the moment it is published on the Website unless otherwise provided by the new version of the Privacy Policy.

9.3. All proposals or questions regarding this Privacy Policy should be directed to the “CONTACTS” section.

10. CATEGORIES OF PERSONAL DATA COLLECTED BY THE APPLICATION

The “b.smart” application may collect the following data:

  • Identifiers: Android device ID / IMEI
  • Activity data: login/logout time, used application features
  • Location: approximate, if permission is granted

All collected data is used solely for providing, improving, and supporting the functionality of the application.

11. DATA TRANSFER TO THIRD PARTIES

To ensure the operation of the application, we may use third-party SDKs and services such as:

  • Google Play Services
  • and other similar solutions.

These services may receive anonymized or technical user data in accordance with their own privacy policies. We do not transfer personal data to third parties for advertising or marketing purposes without the user’s consent.

12. WITHDRAWAL OF CONSENT TO DATA PROCESSING

The User may withdraw their consent to the processing of personal data at any time by contacting the contact information provided in the application or on the website. Upon withdrawal of consent, some functionality of the application may be limited.