Privacy Policy

Privacy Policy and Personal Data Protection of the Website

Last Updated: 23rd March 2022

Section 1. Introduction

1. The privacy of our website visitors is very important to us, and we are committed to safeguarding it. This policy explains what we do with your personal data and how we process your personal data.This privacy also explains basic terms of data processing and data sharing that could be conducted by the User in relations with other Users of our Website.
2. Consenting to our use of cookies in accordance with the terms of this policy when you first visit our website permits us to use cookies every time you visit our website.

Section 2. General provisions

1. The website https://digital.staff-capital.com (hereinafter – the website) is owned by a sole entrepreneur Artemenko Artemenko, TIN 3094915680 (hereinafter – the company or the Website Owner). All intellectual property rights contained on the website, except as otherwise stated, are the property of the company.
   1. 1. A sole entrepreneur Artemenko Olga, registered under the legislation of Ukraine (address: 04655, Ukraine, Kyiv, street Vikentia Hvoyka 18/14, office 703, TIN 3094915680), is a Controller and a Processor in the meaning prescribed by the General Data Protection Regulation (EU) 2016/679. However, there can be another person which processes personal data on behalf of the Website Owner as a Controller.
2. This Privacy and Personal Data Protection Policy (hereinafter – the Privacy Policy) is valid only under the Terms of Service of the website and does not apply to third party websites. Terms and notions used in this Policy shall be understood in accordance with the Terms of Use.
3. This privacy policy describes the set of legal, administrative, organisational, technical, and other measures taken by the company to ensure the confidentiality and protection of personal data of individuals – consumers who visit the website, except when such information personally and deliberately disclosed by the consumer – the user of the website.
4. The purpose of implementing the policy of confidentiality and privacy and protection of personal data is to prevent public access and disclosure of information owned by the consumer.
5. The Company takes all possible measures to ensure compliance with the measures provided for in this privacy policy.

Section 3. Access to personal data

1. To implement the functions and objectives of the website and other purposes related to civil law relations between the company and the consumer, the consumer, using this website and the services for which the website is created, gives the company permission (consent) to collection, accumulation, processing, storage, and use (including with the use of automated means) of personal data, the owner of which he is.
2. To implement the functions and tasks of the website and other purposes related to civil law relations between the Company and the consumer, the consumer, using this Site and the services for which the Site is created, gives the Company permission (consent) to transfer personal data to third parties.
3. The consumer’s consent to the company for the collection, processing, storage, and use (including using automated means) of personal data and their transfer to third parties is made by affixing a mark to the consumer to authorise the collection, accumulation, processing, storage and use their personal data.

Section 4. Types of personal data collected and processed

1. Technical (programmatic) means of our Website can collect such Personal Data: e-mail, first name, last name, nickname. In order to process Users` orders and payments for our services we also collect and process following personal data: user address (country, city, street, house and apartment number), contact phone number. You (as a user) give your voluntary and undoubted consent for the collection and processing specified Personal Data and its transfer to third parties in order to receive our services and to ensure functioning of the Website and its appropriate work.
2. The above mentioned information, described in paragraph 4.1., may be requested and or collected by us prior to activating Your account on the Website and/or any services available through the Website.
3. Any doubts as to validity, authenticity and genuineness of the information, provided by You shall be considered a valid reason to deny Your access to our Website and/or services. The User (You) hereby expressly consents, represents and warrants that any and all information provided to Us is valid, current, complete and accurate.
4. In order to use all the functions of our Website, in particular the functions implemented through the “Groups” and “Events” sections of the Website, the User may voluntarily and on his (her) own discretion provide the following data for additional processing: User photo, User date of birth, User gender, User professional experience, links to the social networks (Facebook, LinkedIn, Twitter), User biographical information in the amount provided at the discretion of the User. Implementation of the functionality of the “Events” section of the Website could also lead to processing of the User geolocation data.
5. Personal Data Collected from all the Users, including non-registered Users​. We collect the Personal Data from running the Website and use information, provided to Us by You, sent to Us by Your computer, mobile phone, or other access device, which may include Your IP address, device information including, but not limited to, identifier, name, and type, operating system, mobile network information and standard web log information, such as Your browser type, and the pages You accessed on Our Website. You (as a user) give your voluntary and undoubted consent for the collection and processing specified data and its transfer to third parties in order to implement functioning of the Website and its appropriate work.
6. We also collect and store such information as: User requests in support regarding the work of the Website, its related services and other issues.
7. When You access the Website and/or use Our services We (or Google Analytics or similar service provider on our behalf) may place small data files called cookies on Your computer or other device. We use these technologies to recognize You as our User; customize our Website and advertising; measure promotional effectiveness and collect information about Your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.
   • 7.1. Most browsers are initially configured to accept cookies. You may control the use of cookies within your internet browsers’ settings. You should refer to the instructions of your browser, the “Help” section or similar resource to learn more about how to manage cookies and possibly reset your browser settings to refuse all cookies. Or, you could specify in your browser settings that you want to be notified when cookies are sent. However, if you do not accept cookies, some pages on our Website may not display correctly and/or some functions may be impaired. If you have any questions regarding the rules of disabling cookies, please check with your browser vendor or manufacturer.
8. Protecting child’s privacy.  Our Website are not designed for use by anyone under the age of 18. If you are a person under the age of 18 years, you should withhold from using Our Website. If you are a parent or guardian and believe your child (a person under the age of 18 years) is using Our Website, please contact us to remove your child’s account. We reserve the right to ask you for verification of your relationship to the child before we honor such a request. However, as parent, you should understand that you are legally liable for any actions of your child.

Section 5. Term and place of storage of Personal Data

1. Personal data, for the collection, accumulation, processing, storage, and use of which the consumer provides access to the company are stored indefinitely, unless otherwise provided by the legislation of Ukraine or the will of the consumer.
2. The place of storage of personal data of the consumer (visitor) is Ukraine.
3. The location of the Company is Ukraine.

Section 6. Using Personal Information

Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.

We may use your personal information for the following:

1. Administering our website and business
2. Personalising our website for you
3. Enabling the visitor to use of the services available on our website
4. Sending you goods purchased through our website
5. Supplying services purchased through our website
6. Sending statements, invoices, and payment reminders to you, and collecting payments from the visitor.
7. Sending to the visitor on-marketing commercial communications.
8. Sending to the visitor email notifications those have been specifically requested.
9. Sending to the visitor our email newsletter if the visitor is signed up for it (the visitor can unsubscribe at any time).
10. Sending to the visitor marketing communications relating to our business or the businesses of third parties which we think may be of interest to you.
11. Providing third parties with statistical information about our users.
12. Dealing with inquiries and complaints made by or about to the visitor relating to our website.
13. Keeping our website secure and prevent fraud.
14. Verifying compliance with the terms and conditions governing the use of our website.
15. Other uses. If the visitor submits personal information for publication on our website, we will publish and otherwise use that information in accordance with the license to the visitor grants us.

To the visitor’s privacy settings can be used to limit the publication of your information on the website and can be adjusted using privacy controls on the website.

We will not, without your expressed consent, supply your personal information to any third party for their or any other third party’s direct marketing.

Section 7. Disclosing personal information

The company has the right to distribute any personal data of the consumer only with the appropriate permission of the consumer.

We may disclose your personal information without additional agreement of the visitor to any of our employees, officers, insurers, professional advisers, agents, suppliers, or subcontractors as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information to other Users of our Website in order to implement the possibility of “User to User” communication via the Website and in order to implement the functionality of the “Groups” and “Events” sections of the Website. The terms of such disclosure are specified in section 8. of this Policy.

We also may disclose your personal information:

1. to the extent that we are required to do so by law;
2. in connection with any ongoing or prospective legal proceedings;
3. to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
4. to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
5. to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
6. The company has the right to disseminate personal data of the consumer if the information obtained from the personal data base is socially necessary, i.e., is a matter of public interest, and the public’s right to know such information outweighs the potential harm of concealing it.

Except as provided in this policy, we will not provide your personal information to third parties.

Section 8. Data processing and data sharing when using the “Groups” and “Events” sections of the Website

1. According to the Annex №2 of the DIGITAL STAFF CAPITAL TERMS OF SERVICET the “GROUPS” section provides the opportunity to create public and closed groups, which are available for other Users. The “GROUPS” section also allow Users to share content, to message each other and to invite each other to join created groups. The “EVENTS” section provides the opportunity to create events, to edit events, to invite other Users to participate in events and to join events. The “EVENTS” section also allow Users to message each other, to edit lists of event participants, to see a list of events.
2. The described functionality of the “GROUPS” section and the “EVENTS” section of the Website provides Users with a theoretical possibility of processing and/or sharing Users personal data in a private messages and/or in a public posts. Doing so Users should respects rights of other Users, as a data subjects, and to comply with the terms of the General Data Protection Regulation (EU) 2016/679 and with the terms of this Privacy Policy.
3. When using the “Groups” and “Events” sections of the Website, the following User personal data may be available for viewing by other Users of the Website: e-mail, first name, last name, nickname; User photo, User date of birth, User gender, User professional experience, links to the User social networks accounts, User biographical information in the amount provided at the discretion of the specific User, User geolocation data.
   • 3.1. By using the relevant features of the Website the User may conceal the display of his (her) personal data to other Users of the Website, with the exception of the following personal data: first name, nickname.
4. Users are prohibited to use the data of other Users outside the Information system of our Website and/or for any purpose other than the purpose of communication between Users within the Information system of our Website. Users are solely responsible for any negative consequences of violating this rule. Users who violate the rights of other Users, as a data subjects, are liable in accordance with the current legislation in the field of data protection.
5. We are not responsible for the consequences of any violations and/or facts of disclosure of personal data that occurred as a result of actions and/or illegal inaction of Users that do not comply with the provisions of this Policy and/or current legislation in the field of data protection.

Section 9. Exemption from the obligation to observe the Privacy Policy

The Company is released from the obligation to comply with the Privacy Policy for Consumer Personal Data if the consumer independently discloses personal data.

Section 10. International data transfers

1. Information that we collect may be stored, processed in, and transferred between any of the countries in which we operate to enable us to use the information in accordance with this policy.
2. Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America, Japan, China, and India.
3. We will take all steps reasonably necessary to ensure that Your Personal Data is treated securely and in accordance with this Policy.
4. You expressly agree to the transfers of personal information described in this Section.

Section 11. Security of your personal information

1. We will take reasonable technical and organisational precautions to prevent the loss, misuse, or alteration of your personal information.
2. We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
3. All electronic financial transactions entered through our website will be protected by encryption technology.
4. You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
5. You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
6. The following recommendations could help you to secure your account and your password: 1) never reveal your passwords to others; 2) use unique password for your account; 3)  use multi-factor authentication (if available); 4) use password with at least 16 characters whenever possible.

Section 12. Rights of the visitor (consumer) as a personal data subject

1. The  User, in respect of his own personal data provided for the collection, accumulation, processing, storage and use of the Company, has all the rights in accordance with the provisions of the General Data Protection Regulation (EU) 2016/679. The User, as a data subject, in particular, has the right to:

1. Know about the sources of collection, the location of their personal data, the purpose of their processing, the location of the company;
2. Receive information on the conditions for granting access to personal data;
3. To access your personal data;
4. Receive information regarding whether his personal data is processed;
5. Submit a reasoned request by the Company to object to the processing of its personal data;
6. Make a reasoned request to change or destroy your personal data if this data is processed illegally or is inaccurate;
7. To protect their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protect against the provision of information that is inaccurate or tarnishes the honour, dignity and business reputation of an individual;
8. Complain about the processing of your personal data to the Commissioner for Human Rights of the Verkhovna Rada of Ukraine or to the court;
9. Apply legal remedies in case of violation of the legislation on personal data protection;
10. Make reservations regarding the restriction of the right to the processing of your personal data during the consent;
11. Withdraw consent to the processing of personal data;
12. Know the mechanism of automatic processing of personal data;
13. To protect against an automated decision that has legal consequences for him.

Section 13. Destruction and deletion of personal data

1. Personal data, for the collection, accumulation, processing, storage, and use of which the consumer provides access to the Company shall be deleted or destroyed in the case of:
   • termination of legal relations between the consumer and the company;
   • issuance of a relevant instruction of the Commissioner of the Verkhovna Rada for Human Rights or officials designated by him to the Secretariat of the Commissioner for Human Rights of the Verkhovna Rada;
   • entry into force of a court decision on the removal or destruction of personal data.

Section 14.  Using External Links

The company’s website may contain links to external websites operated by representatives not affiliated with the company. Once a link is clicked, we no longer have any influence on the collection, storage or processing of personal information that is transmitted when the link is clicked (for example, the IP address or the address of the page on which the link is located).

The behavior of third parties is also beyond our control, meaning our company is not responsible for the processing of personal data by a third party.

Section 15. Using of cookies

1. Generic cookies

We use cookies and active components (e.g., Java Script) to track the wishes of visitors and optimize the design of the website.

Cookies are small text files that are stored on your computer when you visit a website. You can delete cookies if you wish. However, in this case, some functions of the web pages will not be available. For information about deleting cookies, see your browser manual.

Our company allows you to control the use of cookies. To do this, click on the “Setting cookies” link in the footer. This link will provide you with additional information on the use of cookies. In addition, you can set the cookies you wish to use.

Already at the first (mandatory) and second (admissible) stages, anonymous determination of access parameters is carried out using the so-called session cookies. At stage 3 (static), cookies are stored on your computer for 12 months.

2. Third party cookies

The website may include content and services from other sources (e.g., YouTube, Facebook, Google, Twitter), which in turn may use cookies and active components. The Company is not responsible for the processing of personal data by these sources.

Please note that the cookie settings configuration used by our Company does not affect cookies and active components of other sources (for example, YouTube, Facebook, Google, Twitter).

Please refer to the websites of the respective sources for information on data processing.

Section 16. Use of social plugins as part of social media

1. Facebook

The company’s website uses social plugins from the social network Facebook Inc., Palo Alto, California, USA (“Facebook”). Plugins are identified with the Facebook logo and the prefix “Facebook”, “like” or “share”.

When visiting the pages of our website, such plug-ins are initially disabled. Plugins are disabled until you click the corresponding button. By enabling these plug-ins, you establish a connection with Facebook and consent to the transfer of data to Facebook. If you are registered with Facebook, Facebook may link your visit to your Facebook profile. When you click on such a button, the relevant information is transmitted by your browser to Facebook and stored there.

For information about the purpose and scope of the information collected, further processing and use of data by Facebook, your rights and the settings you can use to protect your privacy, please see Facebook’s data protection notice. If you opt out of having Facebook collect your data while you are on our site, you must log out of Facebook before visiting our site.

2. YouTube

The company’s website uses the YouTube video platform, which is operated by YouTube LLC, 901 Chery Avenue, CA 94066, USA. YouTube is a service that allows you to play video and audio files.

When you load a page on our site, the integrated YouTube player allows you to establish a connection with YouTube to enable the technical transfer of audio and video files. When a connection to YouTube is established, the data is transferred to YouTube.

For information about the purpose and extent of the information collected, the further processing and use of data by YouTube, your rights and the settings you can use to protect your privacy, please see YouTube’s data protection notice.

3. Twitter

The company’s website uses plug-ins from the social network Twitter, which is operated by Twitter inc., 795 st. Folsom 600, San Francisco, CA 94107, USA (“Twitter”). Plugins are identified with a Twitter username or “tweet” prefix.

When visiting the pages of our website, such plug-ins are initially disabled. Plugins are disabled until you click the corresponding button. By enabling such plug-ins, you establish a connection with Twitter and consent to the transmission of data to Twitter. If you are a member of the Twitter network, Twitter may link your visit to your Twitter profile. When you click on this button, the relevant information is transmitted by your browser to Twitter and stored there.

For information about the purpose and extent of the information collected, further processing and use of data by Twitter, your rights and the settings you can use to protect your privacy, please see Twitter’s data protection notice.

Section 17. Amendments of this policy

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you understand any changes to this policy. We may notify you of changes to this policy by email or through the private messaging system on our website.

Section 18. Withdrawal of Consent

You can withdraw your consent to the collection, processing, and use of your personal data at any time by sending a corresponding message to cancellation@staff-capital.com

In this case, your personal data will be deleted. This does not apply to information for settlement purposes or that is subject to retention under legal circumstances.

Section 19. Contacts

For more information or to make suggestions and comments regarding the processing of your personal data, you can contact our data protection officer by sending an appropriate message to contact@staff-capital.com

04655, Ukraine, Kyiv, street Vikentia Hvoyka 18/14, office 703

+38 (095)304-84-04

+38 (067)508-44-61

If you have questions, requests, or concerns regarding your privacy and rights, please let us know how we can help.