PRIVACY POLICY AND PERSONAL DATA PROTECTION

(effective from February 20, 2025)

The platform located at the following address on the Internet: https://tonversity.com/ (hereinafter referred to as the ‘Platform’ or ‘Website’), as well as the provision of services listed on the Platform (hereinafter referred to as the ‘Services’), is operated by the owner company acting in accordance with the laws of Ukraine (hereinafter referred to as the ‘Owner’).

This Privacy Policy and Personal Data Protection Policy (hereinafter referred to as the ‘Privacy Policy’) applies to all information that the Platform Owner and/or the Website Administration may collect about the Visitor or Customer while using the Website or receiving Services, programs, and products as part of the provision of these Services.

This Privacy Policy defines the procedure for processing personal data by the Owner, the types of personal data collected, the purposes of processing such personal data, the Owner's interaction with third parties, security measures to protect personal data, conditions for access to personal data, as well as contact information for the Customer to request access, make changes, block, or delete personal data, and address any questions the Visitor or Customer may have regarding personal data protection practices.

TERMS AND DEFINITIONS

Website / Platform – a website owned by the Owner, located at https://tonversity.com/ on the Internet, and managed by the Website Administration.
Website Administration – authorised individuals responsible for managing the Website, who organise and carry out the processing of Personal Data, as well as determine the purposes of processing Personal Data, the composition of Personal Data subject to processing, and the actions or operations performed with Personal Data
User Agreement – a document published on the Website, regulating the relationship between Customers, Visitors of the Platform, and the Owner in the process of providing Services. The User Agreement constitutes a public offer agreement and an adhesion contract.
Visitor – any natural person who has access to the Website and uses it via the Internet.
Customer – a Visitor who has accepted the User Agreement and placed an Order on the Website, thereby becoming the recipient (consumer) of Services under the User Agreement.
Personal Data – any information that directly or indirectly relates to a specific natural person (data subject).
Services – services provided by the Owner of the Website, the list, type, composition, procedure for provision, and other characteristics of which are specified in the User Agreement and published on the Website
Processing of Personal Data – any action (operation) or set of actions (operations) performed with or without the use of automated means on Personal Data, including collection, recording, systematisation, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision, access), blocking, deletion, or destruction of Personal Data.
Confidentiality of Personal Data – a mandatory requirement for the Website Administration or any other person who has gained access to Personal Data not to disclose or distribute it without the consent of the data subject or another legal basis.
This Privacy Policy may use terms not defined in this section. In such cases, the interpretation of the terminology used in the Privacy Policy shall be carried out in accordance with the text of this Privacy Policy. If an unambiguous interpretation of a term is not found in the Privacy Policy, reference should be made primarily to materials published on the Website, and secondly, to definitions and interpretations generally accepted on the Internet.

GENERAL PROVISIONS

By using the Platform, the Visitor / Customer automatically and fully agrees to this Privacy Policy and the terms of Personal Data processing.
If the Visitor does not agree with the terms of this Privacy Policy, they must discontinue use of the Website and leave it immediately.
This Privacy Policy applies to the Website, Services, and Mobile Application.
The Website does not control and is not responsible for third-party websites that the Visitor may access via links available on the Website.
The Website Administration does not verify the accuracy of Personal Data provided by the Visitor / Customer.
The Website Administration is the controller of personal data of authorised Customers of the Services. A controller of personal data is a person who determines the purpose and means of collecting Personal Data.

SUBJECT OF THE PRIVACY POLICY

This Privacy Policy establishes the Website Administration’s obligations regarding the nondisclosure and protection of the confidentiality of Personal Data, which the Customer must provide when registering a personal account on the Platform or while using the Platform, and which the Visitor provides when using the Platform.
The Personal Data permitted for processing under this Privacy Policy is provided by the Customer by filling in designated forms on the Platform or in a free format and may include the following information:
- - Full name of the Customer;
- - Contact telephone number of the Customer;
- - Customer’s email address;
- - Other confidential personal information or contact details of the Customer.
In addition to the data specified in clause 3.2, the Website Administration reserves the right to automatically collect the following data during the Visitor's / Customer's use of the Platform or its individual pages:
- - IP address of the electronic computing device (computer, phone, tablet, etc.);
- - Information about cookies stored in the browser;
- - Geolocation data (country, state or region, GPS location);
- - Information about the electronic computing devices (computer, phone, tablet, etc.);
- - Browser information, including name, version, etc.;
- - Time of access to the Website;
- - URLs of the Website pages visited by the Visitor / Customer;
- - URLs of previous pages from which the Visitor accessed the Website.
Disabling cookies in the Visitor’s browser may result in limited access to certain parts of the Website.
The Website collects confidential data specified in clauses 3.2 and 3.3 of this Privacy Policy for the purpose of identifying and resolving Website technical issues, monitoring Website traffic and load, ensuring the proper provision of Services, tracking Visitor / Customer behaviour on the Website, and for analytical, statistical, and marketing (advertising) purposes.
Any other personal or confidential information not specified above shall be securely stored and not disclosed, except in cases outlined in clauses 7.2 and 7.3 of this Privacy Policy.
The Website Administration collects information and Personal Data only in the following cases:
- - When the Visitor / Customer uses the Website;
- - When the Customer purchases Services;
- - When the Customer creates or submits a request to create an Account.
The Website Administration does not collect any information that is subject to specific legal restrictions, including data on racial or ethnic origin, political, religious, or philosophical beliefs, membership in political parties or trade unions, criminal convictions, as well as data related to health, sexual life, biometric, or genetic data.
The Customer / Visitor may submit Personal Data via the Internet by:
- - Sending an email;
- - Using the Website;
- - Filling in an application to receive Services.

RESTRICTIONS

By registering or placing an order on the Website, the Visitor / Customer confirms that they have reached the legal age required to independently enter into agreements.
If the Website Administration requests the Visitor / Customer to provide consent for personal data processing, they must be able to do so independently.
If the Visitor / Customer has doubts about their ability to independently give consent for personal data processing, they should contact the relevant data protection authority.
The Website Administration may request additional documents or require the Customer to complete extra procedures to confirm their right to independently provide consent for personal data processing. If the Website Administration has reasonable doubts about the Customer’s age, it may also contact their parents or legal guardians to obtain consent or approval for personal data processing. Until the circumstances are clarified or parental/guardian consent is received, the Website Administration may restrict data processing by temporarily blocking the Customer’s account.

PURPOSES OF DATA COLLECTION

The Website Administration may use the Customer’s Personal Data for the following purposes:
- - Identifying the Customer registered on the Platform to process orders and/or accept the User Agreement.
- - Providing the Customer with access to personalised Platform resources.
- - Establishing feedback with the Customer, including sending notifications, requests related to the Platform’s usage, service provision, and processing inquiries.
- - Determining the Customer’s location to ensure security and prevent fraud.
- - Verifying the accuracy and completeness of the Customer’s Personal Data.
- - Creating an Account, if the Customer has consented to its creation.
- - Informing the Customer about the status of their registration/account creation.
- - Providing Customer Support and Technical Assistance in case of issues related to Platform usage.
- - Sending the Customer, with their consent, product updates, special offers, pricing information, news, and other relevant notifications from the Owner.
- - Conducting advertising activities with the Customer’s consent.
- - Providing the Customer with access to the Owner’s partner websites for obtaining products,updates, and services.
The Customer’s Personal Data may also be used for other purposes not explicitly stated in this Privacy Policy.

DATA STORAGE

The Website Administration retains the Visitor’s / Customer’s Personal Data for as long as necessary to fulfil the purposes outlined in this Privacy Policy, but for no less than six (6) months after the expiration of the Customer’s subscription plan.
The Website Administration stores the Visitor’s / Customer’s Personal Data on its designated cloud storage service.
Data storage may also be managed by a third-party service provider acting on behalf of the Website Administration. If the Website Administration no longer requires specific Visitor / Customer data and there is no legal obligation to retain it, the data will be deleted or stored in a manner that prevents identification of the Visitor / Customer

PROCEDURE AND METHODS OF DATA PROCESSING

The Visitor's / Customer's Personal Data is processed without any time limitations, using any legally permissible method, including automated or non-automated processing in personal data information systems.
By staying on the Platform, the Visitor / Customer automatically agrees that the Website Administration has the right to transfer personal data to third parties exclusively for the purpose of fulfilling obligations under the User Agreement.
The Visitor's / Customer's Personal Data may be transferred to authorized government and judicial authorities only if legally required.
In the event of loss or disclosure of personal data, the Website Administration will inform the Customer about the incident using any available means.
The Website Administration implements necessary organizational and technical measures to protect personal information from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions by third parties.
The Website Administration, together with the Customer, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the Customer's personal data.

OBLIGATIONS

Obligations of the Website Administration The Website Administration is obligated to:
- - Use any obtained information solely for the purposes specified in Section 5 of this Privacy Policy.
- - Ensure the confidentiality and security of Personal Data.
- - Not disclose, sell, exchange, publish, or otherwise share the Customer’s Personal Data without prior written consent, except as provided in Section 7.3 of this Privacy Policy.
- - Take precautionary measures to protect the confidentiality of the Customer’s Personal Data in accordance with industry best practices.
- - Block the Customer's Personal Data upon request by the Customer, their legal representative, or an authorized data protection authority, for the duration of an investigation, if inaccurate data or unauthorized activities are identified.
Obligations of the Customer The Customer is obligated to:
- - Provide accurate and truthful personal data required to use the Platform and receive Services.
- - Update or supplement personal data if any changes occur.
- - Take measures to protect access to their confidential information stored on the Platform.

LIABILITY

The Website Administration is liable for damages incurred by the Customer due to unlawful use of personal data, in accordance with the current legislation of Ukraine, except in cases specified in Sections 7.3 and 9.2 of this Privacy Policy.
The Website Administration is not liable for the loss or disclosure of Personal Information if:
- - The information was already public at the time of its loss or disclosure.
- - The information was obtained from a third party before being received by the Website Administration.
- - The information was disclosed with the consent of the Customer / Visitor.
In all matters not covered by this section, the Website Administration is liable in accordance with the current legislation of Ukraine.

DISPUTE RESOLUTION

The Visitor / Customer and the Website Administration shall resolve all disputes and disagreements arising from matters covered by this Privacy Policy through negotiations.
If no agreement is reached, the dispute will be referred to a court at the location of the defendant, in accordance with the procedural laws of Ukraine.

FINAL PROVISIONS

The Website Administration reserves the right to modify this Privacy Policy without obtaining consent or notifying the Visitor / Customer.
The new version of the Privacy Policy takes effect upon its publication on the Website, unless otherwise specified in the updated version.
This Privacy Policy is available on the Website at: https://tonversity.com/.
Any proposals or questions regarding this Privacy Policy should be sent to the following email address: [email protected] .
This Privacy Policy complies with the legislation of Ukraine on personal data protection and provides detailed information on data collection, purposes, processing methods, usage, and protection.