PRIVACY POLICY FOR USER GENERATED COTENT
PRIVACY POLICY FOR USER GENERATED COTENT
This Privacy Policy (hereinafter – the “Policy”) provides you with information on how joint data controllers, LIMITED LIABILITY COMPANY “UKRAINIAN GEARS”, SIA “UGEARS INTERNATIONAL TRADE COMPANY” and UGEARS DISTRIBUTION s.r.o. (hereinafter - “we”, “us” and “our”) process (collect, store, use, share, transfer disclose by transmission, disseminate or otherwise make available, align or combine, restrict, erase or destruct etc.) personal data received according to our User generated content terms and conditions (hereinafter - the “UGC T&C”).
This Policy applies only to the processing of personal data collected according to this Policy. If you provide your personal data to a third party (for instance, Facebook of Instagram), the processing of your personal data will be subject to the policies and business practices of the respective third party. Joint data controllers are not responsible for such third party’s compliance with the legislation regulating processing of personal data.
Personal data processed, purposes and legal basis for processing
We may process the following types of your personal data: your given name, surname and middle name/patronymic, alias under which you are registered on social media, reference to your social media account(s).
This data is processed for the following purposes:
a) to copy, use, publish, adapt, modify, translate, create derivative works, display, reproduce, process, transmit, include, make available to the public, distribute, sublicense, complement with text(s), picture(s) and/or video(s) your photo(s), video(s) and/or stories and/or post(s) (hereinafter - the “UGC”);
b) to confirm that we have received from you license, permission, consent and rights to your UGC;
c) to identify and/or attribute your UGC in our internal and external email and social media communications/publications;
d) to have records concerning license, permission, consent and rights to your UGC that you provided
us with in accordance with the UGC T&C along with records concerning your UGC in our computer systems/databases.
We process your personal data based on legitimate interest we pursue as specified below.
We do not collect special categories of personal data envisaged by Article 9 of the General Data Protection Regulation (hereinafter – the “GDPR”).
How personal data is collected and used
You provide your personal data when you send us “Ugears_UGC_yes” message in the corresponding conversational exchange and thus grant us license, permission, consent and rights to your UGC as specified in the UGC T&C.
We use your personal data while performing actions specified in clauses “a”, “b”, “c” and “d” of section “Personal data processed, purposes and legal basis for processing” of this Policy.
We do not use automated decision-making systems including profiling while processing your personal data.
You may send a notice/request at any time that you object to the processing of your personal data or that you no longer wish joint data controllers to continue processing your personal or that you wish to restrict the processing of your personal data (to opt out from certain use of your personal data).
Sharing personal data with third parties
The activities specified in clauses “a”, “b”, “c” and “d” of “Personal data processed, purposes and legal basis for processing” section of this Policy with regard to your UGC suggest possible publicizing of your personal data to a broader audience.
Your personal data may also be shared with third parties service providers we engaged to assist us with the activity specified in clauses “a”, “b”, “c” and “d” of “Personal data processed, purposes and legal basis for processing” section of this Policy.
The sharing above may result in transferring your personal data out of the EEA. Any transfer of personal data out of the EEA shall take place if the EU Commission has decided that the corresponding country ensures an adequate level of protection of personal data or if appropriate safeguards are provided in the form of the Standard Contractual Clauses for the protection of personal data. You may contact us to obtain a copy of such safeguards.
To who and when access to your personal data is provided
Access to your personal data (disclosure by transmission, dissemination or otherwise making your personal data available) may be provided to regulatory, law enforcement and/or other agencies:
- on the basis of a request provided that there are sufficient grounds to believe that it is necessary according to the applicable law;
- if there is a reason to believe that providing access to your personal data is necessary to track, prevent, or investigate fraud, unauthorized use of the account credentials, other harmful or illegal acts;
- if granting access to your personal data is necessary for the protection of joint data controllers’ rights and/or compliance with our obligation arising out of request, investigation or trial.
Storage period
The personal data storage period equals to the period of time during which your UGC is being used.
At the end of the respective period, the relevant data will be systematically deleted, provided it is no longer required for protection of legal interests, compliance with the request lodged by a supervisory or law enforcement agency or an obligation arising in connection with request, investigation or trial.
Security
The employees engaged in processing of your personal data are obliged to adhere to the security principles and current provisions on personal data protection.
Reasonable and appropriate measures are taken to protect your personal data, including against the risks of unintentional or unlawful destruction, manipulation, damage, alteration, or unauthorized disclosure or access.
Your rights
You have the following rights:
- the right to obtain confirmation as to whether or not your personal data are being processed, and, where that is the case, to access to such personal data and information;
- the right to obtain the rectification (correction) of your inaccurate personal data including the right to have your incomplete personal data completed;
- the right to obtain the erasure of your personal data;
- the right to obtain restriction of processing (the right to opt out from certain use of your personal data, including but not limited to from direct marketing/personalized advertising);
- the right to request information on the recipients of your personal data;
- the right to receive your personal data that you have provided, in a structured, commonly used and machine-readable format and the right to transmit such data to another controller (data portability);
- the right to object at any time to processing of your personal data;
- the right not to be a subject to a decision based solely on automated processing, including profiling;
- the right to withdraw consent to the processing of your personal data at any time, without affecting the lawfulness of processing based on consent before the withdrawal;
- the right to lodge a complaint with the competent supervisory authority or court;
- other rights provided by applicable laws.
If you have any questions about your rights or would like to exercise your rights, you may send a message to: privacy@ugearsmodels.com. Please be aware of our necessity to perform unambiguous identification of your person.
Age restrictions
We do not knowingly process personal data of children.
By providing the license, permission, consent and rights to your UGC, you confirm that you have reached the majority age in accordance with the laws applicable in your place of residence.
Please contact us at privacy@ugearsmodels.com if you have provided us with any personal data about children so we will be able to erase the data. Please be aware that we may request additional information necessary to identify your information and satisfy your request.
Confidentiality notice
By providing the license, permission, consent and rights to your UGC you confirm that your personal data is not classified as confidential.
Date of entry into force and change to this Policy
This Policy becomes effective upon posting at this specially designated section of https://ugearsmodels.com/ website.
Joint data controllers reserve the right to change this Policy at any time. Changes to the Policy take effect immediately after their posting at this specially designated section of https://ugearsmodels.com/ website and apply to those who have consented to the processing of personal data after the corresponding changes have been posted as specified herein.
Contact details:
Joint data controllers:
LLC “UKRAINIAN GEARS”
Ukraine, 03151, Kyiv, street Ochakivska/Ochakivskyi lane, building 5/6
(role, responsibility and liability of this joint controller for compliance with obligations under the GDPR, in particular as regards the exercising of your rights and duties to provide information envisaged by the GDPR: please consult clauses “a”, “b”, “c” and “d” of “Personal data processed, purposes and legal basis for processing” section of this Policy)
SIA “UGEARS INTERNATIONAL TRADE COMPANY”
The Republic of Latvia, LV-2167, Mārupes nov., Vētras, “Asarīši 3"
(role, responsibility and liability of this joint controller for compliance with obligations under the GDPR, in particular as regards the exercising of your rights and duties to provide information envisaged by the GDPR: please consult clauses “a”, “b”, “c” and “d” of “Personal data processed, purposes and legal basis for processing” section of this Policy)
The Czech Republic, 110 00 Praha 1, Staré Město, Kaprova 42/14
(role, responsibility and liability of this joint controller for compliance with obligations under the GDPR, in particular as regards the exercising of your rights and duties to provide information envisaged by the GDPR: please consult clauses “a”, “b”, “c” and “d” of “Personal data processed, purposes and legal basis for processing” section of this Policy)
Joint controllers agreed to work in close cooperation to secure the most efficient exercise of your rights.
