This Policy of personal data processing (hereinafter referred to as “Policy”) is prepared by the Administration of the Service in accordance with the provisions and requirements of the current legislation of the country of Montenegro, “On Personal Data”, and is aimed at defining the conditions regarding the receipt (collection) of Personal Data of Users of the Service, their use and other conditions of processing of Personal Data of Users.
This Policy is a legally binding document for Users using the Service in accordance with its main purpose. Each User undertakes to familiarize with this Policy before using the Service.
Acceptance of the present Policy is carried out by the User by means of performing by the User of conclusive (actual) actions, indicating the reading and acceptance of the Policy, namely by putting a “tick” (mark) on the consent and acceptance of the present Policy in a special section (special form) of the Service at the registration of the User or at the execution of the Transaction by the User, which indicates the intention, will, desire and consent of the User to observe and fulfill the present Policy.
Acceptance of the Policy means familiarization, understanding of all together and individually the terms of the Policy, full, unconditional and unconditional consent of the User with its provisions and requirements, as well as assuming the obligation to strictly comply with all the rules defined in the Policy.
The Administration of the Service and the User are hereinafter jointly referred to in the text of the Policy as - “Parties”, and individually as - “Party”.
1.1. For the purposes of this Policy, the following terms are used with the following meaning:
1.1.1. Deally Service or Service - a set of information and technical solutions placed in the Internet at the address: www.deally.me , providing the possibility of direct interaction and organization of conclusion and execution of the Transaction between the Seller and the Buyer, as well as safe mutual settlements between them.
1.1.2. Administration of the Service - Deally Ltd., Montenegro, Podgorica, Masa Durovica 13/a, represented by its authorized representative (moderator), which has the rights to use, manage and dispose of the Service. The Administration of the Service is the operator of personal data processing in the interpretation established by the Federal Law of the country of Montenegro “On Personal Data”.
1.1.3. User - a person who accesses the Service in order to receive services from the Administration of the Service, in particular a Seller or a Buyer.
1.1.4. Personal Data - any information relating to a directly or indirectly defined or identifiable natural person (subject of personal data).
1.1.5. Processing of Personal Data - any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
1.2. The Policy may use terms not defined in clause 1.1. of this Policy. In such cases, the interpretation of the terms shall be made in accordance with other legal documentation posted on the Service, as well as in accordance with the text and meaning of this Policy.
1.3. In the absence of an unambiguous interpretation of a term in the text of the Policy and the Public Offer, one should be guided, first, by the interpretation of terms used on the Service, including in other legal documentation posted on the Service; second, by the legislation of the Russian Federation and business practices in the relevant area of activity.
2. Purpose of the Policy. Purpose, methods and legal grounds of personal data processing
2.1. This Policy is aimed at ensuring proper protection of Users' Personal Data from unauthorized access to it by third parties, determining the procedure for obtaining, providing and using Users' Personal Data.
2.2. Purposes of Processing of the User's Personal Data:
2.2.1. Execution by the Administration of the Service of its obligations to the User provided by the Agency Agreement and Service Agreement;
2.2.2. Organization of conclusion of Transactions between Users (Sellers and Buyers);
2.2.3. Organization of mutual settlements between Users (Sellers and Buyers);
2.2.4. Providing the User with an opportunity to use the Service in accordance with its functional purpose and orientation;
2.2.5. Forming statistics of the Service usage anonymously and in generalized form for efficient service of Users and providing better performance of the Service, providing user preferences, anti-fraud, performance analysis.
2.3. The Administration of the Service sets as its most important goal and condition for the realization of its activities the observance of human and civil rights and freedoms in the processing of Personal Data, including the protection of the rights to privacy, personal and family secrecy.
2.4. Personal Data is processed by the Administration of the Service in the ways listed in paragraph 1.1.5 of the Privacy Policy in accordance with the purposes set out in this section of the Policy.
2.5. The legal basis for Processing of Users' Personal Data is:
- personal consent to the Processing of Personal Data provided by the User by Acceptance of this Policy.
3.1. The Administration of the Service carries out and/or may carry out processing of the following Personal Data of Users (composition of Personal Data):
- e-mail address;
- telephone number.
The purposes of processing such Personal Data (information) are specified in paragraph 2.2. of this Policy.
3.2. The Personal Data specified in clause 3.1. of this Policy is processed in an automated way. of the Policy are processed in an automated way (on a computer, server).
3.3. When using the Service by the User, the Administration of the Service in the automated mode also receives information from program, technical and hardware services (software, etc.) used by the User when viewing the web pages of the Service, including, but not limited to the following:
- information about the hardware and software devices used by the User when visiting the Service, including the model and version of the operating system, unique device identifiers, and data about the User's mobile network;
- information recorded in server logs, in particular, information about the User's search queries, cookies, IP address, system malfunctions, cookie data, data about the User's browsing of certain web pages of the Service;
- information about the territorial location of the User, provided via the Internet, etc.;
- information about the domain (subdomain) of the User's provider, the country of its location, etc.
The purpose of the Processing of such Personal Data (information) is to generate statistics of the use of the Service anonymously and in a generalized form for the effective service of the User and to ensure better performance of the Service, to ensure user preferences, to combat fraud, to analyze performance.
3.4. Placement of Personal Data on the Service, their provision to the Administration of the Service by the User pursues the purpose - fulfillment of mutual obligations between the Administration of the Service and Users under the contracts specified in paragraphs 2.2. and 2.5. of the Privacy Policy. Privacy Policy.
3.5. The use of Personal Data about the User is carried out in accordance with the purposes defined in Section 2 and 3 of this Policy, and is inadmissible for any purposes other than those corresponding to the subject matter of the Service.
3.6. The Administration of the Service undertakes not to provide any Personal Data about Users to individuals and organizations that claim possible misuse of such information (sending unauthorized advertising, spam, providing information to other persons, etc.).
3.7. The Administration of the Service processes only those Personal Data of users, which were placed on the Service, provided by the User. Personal Data of Users is processed by means of hardware and software and technical means of the Service, as well as in manual mode.
4.1. The User hereby acknowledges and agrees that the posting of Personal Data on the Service, as well as their transfer to the Administration of the Service is done independently, voluntarily and at its sole discretion. By posting their Personal Data on the Service, the User confirms that they do so voluntarily, and that they voluntarily provide them to the Administration of the Service for processing.
4.2. The User hereby consents to the Processing of his/her Personal Data in accordance with the provisions of the applicable laws of the country of Montenegro. The Administration of the Service has the right to use the User's Personal Data in order to fulfill its obligations to the User, including those specified in Section 2 of this Policy, in accordance with the terms of the applicable legislation on Personal Data.
4.3. The User hereby consents to receive from the Administration of the Service various sms-newsletters, e-mails and other forms of sending/receiving information, including advertising content.
4.4. Due to the peculiarity of the Service, the Administration of the Service cannot verify the reliability of information provided or received from Users, does not control the legal and legal capacity of Users. It is presumed and the Administration of the Service assumes that the User in all cases without exception provides complete and accurate information about themselves and keeps this information up to date.
4.5. The Administration of the Service undertakes not to place Personal Data of other persons on the Service, as well as not to use the Personal Data of other Users in any way that does not comply with the requirements of the legislation of the country of Montenegro, for illegal or unlawful purposes, for profit and any other purposes that do not correspond to the purposes of the Service.
5.1. The Administration of the Service has no right, except for the cases specified in paragraph 5.2. of this Policy, to transfer the Personal Data about the User to third parties without the User's consent, both on a compensated and non-reimbursed basis.
5.2. The Administration of the Service has the right to transfer information about the User without the User's consent and without prior notice to the User in the following cases, if it is permissible or the Administration of the Service has such an obligation:
- to state authorities, in particular law enforcement agencies, bodies of inquiry and investigation, court upon their reasoned request;
- on the basis of a judicial act to third parties;
- in other cases stipulated by the current legislation.
6.1. The Administration of the Service takes technical, organizational and legal measures to ensure the protection of the User's Personal Data from illegal or accidental access to them, destruction, modification, blocking, copying, distribution, as well as from other illegal actions.
6.2. Such measures include:
6.2.1. Issuing and publishing this Personal Data Processing Policy on the Service.
6.2.2. Appointing a person responsible for organizing the Processing of Users' Personal Data. Such person is the General Director of the Administration of the Service.
6.2.3. Continuous assessment and control of the risk and harm that may be caused to the User in case of violation of the legislation on Personal Data.
6.2.4. Providing access to Personal Data only to those employees of the Service Administration who actually need it for the performance of their duties and taking into account the purposes of Personal Data Processing.
6.2.5. Recording, systematization, accumulation, storage, clarification (updating, modification), extraction and other means of Processing of Personal Data using databases located in the Netherlands.
6.2.6. For all purposes of Personal Data Processing, the period of Personal Data Processing (Personal Data retention period) is 3 years from the date of the last activity on the Service. The User may withdraw their consent to the Processing of Personal Data at any time by sending a notice to the Service Administration by e-mail to the e-mail address of the Service Administration Deally marked “Withdrawal of consent to the Processing of Personal Data”.
Personal Data is destroyed by erasing it from the servers of the Service Administration.
6.3. In the event that there is a cross-border transfer of Personal Data, the User hereby gives consent to the Service Administration for such transfer. At the same time, the Administration of the Service, prior to the beginning of the trans-border transfer of personal data, is obliged to make sure that the foreign country, to the territory of which the transfer of Personal Data is supposed to be carried out, provides reliable protection of the rights of the subjects of Personal Data. Trans-border transfer of personal data to the territories of foreign countries that do not meet the above requirements may be carried out only if the personal data subject consents in writing to the trans-border transfer of his/her personal data and/or fulfillment of an agreement to which the personal data subject is a Party.
7. Dispute Resolution Procedure
7.1. The Administration of the Service and the User have hereby established a claim pre-trial procedure for settling disagreements and disputes arising from the application of this Policy. The deadline for responding to the submitted claim is 30 business days from the date of its receipt.
7.2. In case of failure to reach an agreement on the disputed issues, the dispute arising from this Policy is subject to judicial review in accordance with the applicable laws of the country of Montenegro.
8.1. Users have the right to send their requests to the Administration of the Service, including requests regarding the use of their Personal Data, as well as to receive information that must be provided by the Administration of the Service at the request of the User in accordance with the legislation on Personal Data, to the e-mail address of the Administration of the Service: help@deally.me
8.2. The Administration of the Service is obliged to consider and send a response to the User's request within 30 days from the receipt of the request.
8.3. All correspondence received by the Administration of the Service from the Users (requests in written or electronic form) refers to restricted information and is not disclosed without the written consent of the User. Personal data and other information about the User who sent the request may not be used without the express consent of the User, except to respond to the subject of the received request or in cases expressly provided for by the legislation of the country of Montenegro.
9.1. This Policy comes into effect from the moment of its posting on the Internet on the Service specified in paragraph 1.1.1. of this Policy.
9.2. This Policy is enacted for an indefinite period of time and shall cease to be in force when it is canceled by the Administration of the Service.
9.3. In case of changes to the Policy, such changes shall come into force from the date of publication of the new version of the Policy on the Service, unless another term of entry into force of changes is not determined additionally at the time of its publication. The Administration of the Service has the right to unilaterally make changes to the text of the Policy.
9.4. The User is obliged to independently control the changes in the provisions of this Policy and bears responsibility and negative consequences associated with non-compliance with this obligation.
9.5. If the User does not agree with the relevant changes, the User must stop using the Service and refuse from the services provided by the Administration of the Service. Otherwise, the continued use of the Service by the User means that the User agrees with the terms of the Policy in the new version.
9.6. The current version of the Policy is located in the relevant section on the Service and is permanently available at: https://deally.me/en/privacy-policy.
9.7. This Policy has been drawn up in the Russian language. If there are any discrepancies between the version of the Policy drafted in Russian and the version of the Policy translated into another language, the provisions of the Policy drafted in Russian shall prevail and be directly applicable.