PRIVACY POLICY 

of the LLC «WebmartGroup»

Last update - on December 28, 2020

For LLC «WebmartGroup» (collectively, “LLC «WebmartGroup»”, “we”, or “us”) ensuring of rights’ and interests’ protection of the Users is one of the most priority issues considering the peculiarities of usage of LLC «WebmartGroup» services. By “Services” we mean applications and games that we control. Provision of personal identifying information is necessary for the User in order to access to LLC «WebmartGroup» services receipt. Non-provision of the respective personal data by the User shall result in inability for the LLC «WebmartGroup» to provide services to the User. LLC «WebmartGroup» company with residence at Belarus, Minsk, Melezha str., 5-1, of. 240 , is the controller and responsible for the Services. 

Within the present privacy policy of the LLC «WebmartGroup» under personal data the information relating to an identified or identifiable User is understood.

Personal data do not include anonymous data that do not relate to an identified or are not identifiable in relation to concrete User as well as depersonalized data.

Purposes of User’s personal data processing: (1) fulfillment of the provisions of the Terms of Use concluded between the User and the LLC «WebmartGroup» (Legal basis - contract); (2) provision of the User’s access to the services provided by the LLC «WebmartGroup» (Legal basis – such data processing is strictly necessary for the service(s) asked); (3) to run analytics and understand how users interact with our product and services in order to continuously improve it (Legal basis - consent); (4) To serve advertising according to the preference and interests of our users and allow the LLC «WebmartGroup» to continue to provide free services and products (Legal basis –consent. The LLC «WebmartGroup» only processes or shares personal data collected through the LLC «WebmartGroup» apps for personalized advertising purposes once you express your consent through the pop-up notice included in one of our apps).

LLC «WebmartGroup» applications can collect the following information about the User (cases of collection are indicated):

1. Information about device or browser within the access to the LLC «WebmartGroup» applications that is processed by automated means, i.e. information about mobile device, including IP-address, operational system, IDFA (Identifier For Advertisers) or Apple/Android ID, technical data regarding device attributes and settings, applications, advertising opt-out signals, in-app events, device motion parameters and carrier.

2. Name, surname, mobile phone number, registration data (login/name/e-mail address and password) in case of registration procedure conducting or in case you directly contact us.

3. Mobile advertising IDs, GPS location (if appropriate permission is given), application usage statistics such as launch times and duration, ad views and click-throughs, if there are advertisements in the application.

4. Any content User downloads into LLC “WebmartGroup” applications such as User photos, place of residence etc., if such a download is possible in the application.

You may have the opportunity to connect to our Services through Facebook Connect when you register for Services or after you have registered for Services. If you connect to Services through Facebook Connect, we will collect, store, and use in accordance with this Policy any and all information you agreed that Facebook could provide to us through its API. This process links our Services to your Facebook profile and we may access, collect and store the following information, among other information, as allowed by you, Facebook’s API, and your Facebook privacy settings: your Facebook name; your profile picture; your email address; your location; other information you make publicly available via Facebook. You may find Facebook’s Privacy Policy below.

The following companies are the Processors of the personal data of the applications of "WebmartGroup" LLC (In case you want to learn more about the services and privacy options please consult their websites and privacy policies):

Our Services allow in-app purchases. In-app purchases are not mandatory and it is up to you whether to pay for accessing such functionality or not. You should know that we don’t process payments directly, payments processed via Apple App Store (Apple Inc., https://www.apple.com/legal/privacy/en-ww/) and through the Google Play Store (Google LLC, https://policies.google.com/privacy). We don’t collect or store payment data, details or payments-related personal data. Payment processing takes place through a payment system, integrated into the app store, appropriate for your platform. 

LLC «WebmartGroup» hereby undertakes not to conduct any disclosure or transfer of the User’s personal data to any third parties, except Processors, mentioned above, without receipt of personal consent of the User.

We work in the international space and provide our Services to our Users around the world. We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located outside Belarus and choose to provide information to us, please note that we transfer the data, including Personal Data, to Belarus and process it there. This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of a personal data as your country does. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Also, it is important to know, If we are bound to disclose your personal data by a judicial order or by a governmental or regulatory authority, we will comply and share the personal data with that body.

The User hereby freely gives, specific, informed and unambiguous consent to the processing of the personal data relating to him or her and mentioned above for the purposes of personal data processing indicated hereto. We will not rent or sell or disclose your personally identifiable information to others. We will use and process your Personal Data only in such cases if you give us your consent or we have legal obligations.

The User has the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Withdrawal is made by the mere notification of the LLC “WebmartGroup” via its Support service, i.e. by sending an e-mail to the address info@adwebmart.com with the topic “Consent withdrawal” or in the Settings menu of the application.

The User is also entitled to:

1. request the access to and rectification or erasure of personal data processed by the LLC «WebmartGroup»;

2. restrict the processing of personal data concerning the User;

3. object to processing of personal data concerning the User;

4. demand for realization of the right to data portability from the LLC «WebmartGroup»;

5. exercise the right to lodge a complaint with a relevant supervisory authority.

6. right to opt-out of direct or target interest advertising on mobile applications by checking the privacy settings on your device settings menu. Please note that even if you use your right to opt-out it you will still receive advertising, but not direct or target interest. On Apple you can opt-out this by going to Settings > Privacy > Advertising and turning on “Limit Ad Tracking”. On Android you can opt-out by going to Settings > Google services > Ads and turning on choosing “Opt out of Ads Personalization”. Please be aware when your personal information that is processed automatically you may object to such processing in some circumstances. Where your personal information is processed for direct marketing purposes, you may ask to cease processing your data for these direct marketing purposes. In order to exercise your right please contact the third party services listed in the paragraph 4 of this Privacy Policy to learn how you can object to processing your data. Most of them have clear instructions on their privacy pages, functional API or other options. Please note that you can opt-out of marketing tracking by emailing the developer account.

7. based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request. We will respond to your request within 30 business days. The User is empowered to request one copy of the personal data undergoing processing free of charge. Any additional copies are provided on a reimbursement basis.

The User is empowered to request one copy of the personal data undergoing processing free of charge. Any additional copies are provided on a reimbursement basis.

LLC «WebmartGroup» uses the safety measures for ensuring the confidentiality of the User’s information as well as for protection of the User’s information from loss, theft, unauthorized access, misuse, amendment or destruction.

The User is obliged to ensure safety of the registration data indicated by him or her for safe usage of LLC «WebmartGroup».

LLC “WebmartGroup” stores the personal data relating to the User for 1 (one) year after closing, termination of the Personal account or uninstalling the application. Upon termination of the mentioned term personal data relating to the User are subject to destruction or depersonalization to ensure anonymity of such information via deletion of the personal identifying information.

Data retention periods for other Processors are indicated by the links above.

Conditions of the present privacy policy of the LLC «WebmartGroup» may be unilaterally changed by the LLC «WebmartGroup» if required under the applicable laws or in other relevant cases with obligatory notification of the Users. New version of the privacy policy enters into force and is subject to observance by the User after the User has expressly agreed to its applicability.

If the User does not agree to the applicability of the new version of the privacy policy of the LLC «WebmartGroup», the User will discontinue the usage of the LLC «WebmartGroup» and will be not allowed to use its Personal account without provision of an unambiguous consent to the applicability of the new version of the PRIVACY POLICY.

Our Services usually have a minimum age requirement of users and are not directed to children, and we do not knowingly collect Personal Data relating to children. Children should never disclose their name, address or phone number, or any personal information, without their parents’ prior permission. We consider a user to be a child if they are under the age of 13, unless more stringent regulation applies in their country of residence. In EU countries, users under the age of 16 are considered children, unless the data protection regulation of their country of residence specifies another age. If you become aware that your child has provided us with Personal information without your consent, please contact us and we will take the required steps to delete such information.

Specific provisions applicable under california privacy law 

This is an additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). We adopted this paragraph to comply with CCPA and any terms defined in the CCPA have the same meaning when used in this notice.

California law requires us to disclose information about the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information. We have provided detailed descriptions above in this policy. In particular, our Services have collected the following categories of personal information from its consumers within the last twelve (12) months:

We do not sell your personal information to third parties. We do share personal information with the Processors of the Personal Data of the Services of mentioned before.

As a California resident, you have the rights listed below:

• You can request information about how we have collected and used your personal information during the past 12 months including the categories of personal information collected, the sources from which we collected personal information, the business or commercial purpose for collecting personal information, and the third parties with whom we shared personal information.
• You can request a copy of the personal information that we have collected about you during the past 12 months. Also, according to the California “Shine the Light” law users who are California residents have the right to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. To make such a request from us, if entitled, please use the contact information listed below.
• You can ask us to delete personal information we have collected from you. We may need certain types of information so that we can provide our Services to you. If you ask us to delete some or all of your information, you may no longer be able to access or use the Services.
• You have the right to be Free from Discrimination. We may not discriminate against you because you have exercised your rights, including, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.
• You have the right to opt out of the sale of Personal Information, which is defined in a way that may include the transfer of data to third parties to personalize ads for you. Please note that the CCPA defines the term “sale” very broadly to include any exchange of data for consideration of any kind, not simply selling your data for monetary compensation. Depending upon the circumstances, the term “sale” could include a company providing a resident’s data to another entity to assist the company with targeted advertising. We do not sell to third parties, and within the last 12 months have not sold, any of your personal information. If you opt out of the ‘sale’ of your information, we will not sell your information, including to our advertising partners, but you may continue to receive ads from our Services, which may not be as tailored to your interests.

You may exercise your California privacy rights described above by emailing us. We will need to confirm your identity (e.g. first name, last name, account name, email address, state of residence, etc.) and California residency to process your requests to exercise your information, access or deletion rights. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

 Specific provisions applicable for eu, efta, and uk residents (“gdpr notice”)

This section applies to individuals in the European Economic Area and the United Kingdom.

If you are a European user, you can also request limitations to the processing of your personal information, object to the processing of your information, or exercise your right to data portability.

You have the right to know what Personal Data we hold about you, how and why we handle your Personal Data. You can ask us for a copy of your Personal Data. If you would like to exercise your right of access please contact us as described below and let us know what information in particular you would like to receive. 

You have the right to request an update or correction to any of your Personal Data which is out of date, incomplete or incorrect. In certain specific circumstances you have the right to ask us to delete your Personal Data which we are holding about you. 

You have the right to delete your personal data.

You have the right to portability of your personal data. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.

You have the right to withdraw your consent at any time if we are processing your personal data with your consent.

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

To request one of these actions, please contact us. We may request information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

If you have any questions relating to the present privacy policy of the LLC «WebmartGroup» or claims arising out of its application, please, refer them to the LLC «WebmartGroup» Support service via the e-mail: info@adwebmart.com. We shall contact you back as soon as possible.

In case of your personal data breach, please, immediately contact the LLC «WebmartGroup» Support service via the e-mail: info@adwebmart.com(mentioning topic “Personal data breach” in your notice with description of the accident occurred).

Contact details of the LLC «WebmartGroup»:

LLC «WebmartGroup»

Belarus, Minsk

Melezha str., 5-1

of. 240, 220102 (zip code)

info@adwebmart.com 

phone: +46855921690