PRIVACY AND DATA PROTECTION POLICY

This Privacy And Data Protection Policy (hereinafter the Policy) defines the regulation of the relationship between KADAM SIA, incorporated under the laws of the Republic of Latvia, located at Rīga, Avotu 23-3, LV-1011 (hereinafter the Company) and YOU (hereinafter the Data Subject) regarding the use of your personal data.

ALL DATA SUBJECTS ARE REQUIRED TO READ THIS POLICY TO UNDERSTAND HOW THE COMPANY COLLECTS AND PROCESSES PERSONAL DATA AND WHAT SECURITY MEASURES ARE BEING APPLIED.

While conducting its activities, the Company adheres all conditions and requirements stipulated by the current legislation of the Republic of Latvia, European legislation including but not limited to the General Data Protection Regulation as well as by other international legislative acts concerning data protection.

1. Definitions

Personal data – means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Special categories of personal data (sensitive data) – means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

Data controller (controller) – means a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Data processor (processor) – means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Data Subject – means any living individual who is the subject of personal data are processed by the Company, including Users, Visitors, independent contractors/employees and other stakeholders.

User – means a data subject who has completed registration procedure at the Website and wanted to use Services or has already used Services.

Visitor – means a data subject who has entered the Website with any purpose.

Third party - means a data subject, whose personal data are processed by the Traffic source as a controller and transferred to the Company for the performance of a contract between the Traffic source and the Company.

Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Profiling – means any form of automated processing of personal data intended to evaluate certain personal aspects relating to a natural person, or to analyses or predict that person’s performance at work, economic situation, location, health, personal preferences, reliability, or behavior. This definition is linked to the right of the data subject to object to profiling and a right to be informed about the existence of profiling, of measures based on profiling and the envisaged effects of profiling on the individual.

Automated decision-making – means an ability to make decisions by technological means without human involvement that produces legal effects concerning tha Data Subject or similarly significantly affects the Data Subject.

Personal data breach – means a breach of security leading to the accidental, or unlawful, destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed..

Consent – means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data.

Website – means the website https://www.kadam.net/. which is owned by the Company as well as subdomains adx.kadam.net, impr.kadxin.net, go.kadxin.net, media.kadxin.net, bidder.kadxin.net, us1impr.kadxin.net, us2impr.kadxin.net.

Services – means posting User’s advertising materials on information resources of another persons and promoting them to specific categories of audience.

Traffic source – means a legal entity which as a controller may transferr to the Company the personal data of the Third Parties on lawfull basis.

Advertiser – means a natural or legal entity which is Company’s business partner and obtain from the Company pseudonimisation information about Third Parties.

Partner – means a legal entity or individual enterpreneur which has concluded agreement with the Company and involved in personal data processing according to this Policy (Traffic source, Advertiser or independent contractors).

Data Protection Authority (DPA) means an independent public authority which is established by a Member State pursuant to the GDPR. In the contents of this Policy the DPA means an Data State Inspectorate of Latvia that is located at the following address Blaumana Street 11/13-11, Riga, LV-1011, Latvia (website: http://www.dvi.gov.lv/lv/).

2. Statement

2.1. In collecting and using of the personal data, the Company is subject to a variety of the legislation controlling how such activities may be carried out and the safeguards that must be put in place to data protect.

2.2. This Policy applies to all Company’s employees, independent contractors, Users, stakeholders and all other subjects that directly or indirectly participate in the personal data processing, including Data Subjects who visit the website https://www.kadam.net/, within Company’s activities as well as subdomains adx.kadam.net, impr.kadxin.net, go.kadxin.net, media.kadxin.net, bidder.kadxin.net, us1impr.kadxin.net, us2impr.kadxin.net.

2.3. This Policy sets out how the Company uses, processes and stores the Data Subjects’ personal information. The Company will obtain that information from Data Subject with his/her permission and consent, or may receive personal data from the Traffic sources to whom Data Subject has given consent to pass this information on to the Company according to this Policy.

2.4. The Data Subjects have a right to apply to the Company or to the DPA about his/her personal data breach if he/she becomes aware of it earlier than the Company.

3. Principles of processing

3.1. During collecting and processing the personal data, the Company adheres the principles provided by the GDPR. The Company’s policies and procedures are designed to ensure compliance with the principles:

(a) Lawfulness, fairness and transparency

Lawfulness – the controller identifies a lawful basis before to process the personal data (for example consent).
Fairness – in order to process fairly, the controller has to make certain information available to the data subjects as practicable. This applies whether the personal data was obtained directly from the data subjects or from other sources.
Transparency – any information and communication relating to the processing of the personal data be easily accessible and easy to understand, and that clear and plain language be used.

(b) Purpose limitation

The personal data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, not be considered to be incompatible with the initial purposes.

(c) Data minimization

The personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

(d) Accuracy

The personal data must be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.

(e) Storage limitation

The personal data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, if only are implementated appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject.

(f) Integrity and confidentiality

The personal data must be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

4. Collected personal data and purposes of processing

4.1. While conducting its activities, the Company collects the following personal data for determined purposes:

Personal dataPurposes
The Users personal data
- Name· for polite appealing to the User
- E-mail· used as login for authorisation in the systems of the Company at the Website

- Telephone number

- ICQ UIN

- Skype login

- Telegram number

· used for communication with the User and providing support with authorisation, account managing, account security, system software errors, Services, bans etc.
- IP address· for prevention frauds related to providing the Services or using systems of the Company.
- HTTP cookies· for fast and easy User authorisation on the Website.
All described above personal data are being processed by the Company to provide Services
E-mail address, ICQ UIN, telephone number Skype login, Telegram number, HTTP cookies also are used for sending to the User most relevant advertising material and offers concerning Services based on the profiling such information about him/her.
The Visitors personal data

- Browser type and version;

- Operation system type and version;

- Information about visited websites;

- Information about advertising materials displayed to the Visitor on the Website;

- Clicks on the advertising materials on the Website.

· prevention frauds related to providing the Services or using systems of the Company.

· displaying to the Visitor most relevant advertising material and offers concerning Services based on the profiling such information about Visitors.

The Partners (or its employees) personal data

- Full name;

- Position;

- E-mail address;

- Ways of communication

· making conversation about contracts performance or other financial/legal issues;

· sending advertising offers concerning the Services.

4.2. The Traffic source may transfer to the Company the following personal data of the Third Parties:

- IP address;

- Browser type and version;

- Operation system type and version;

- Client unique identifier in the system of the Traffic source.

4.3. The Company pseudonimises IP address of the Third Party and encrypts with irreversible hashing method another information about Third Parties immediately after they transferring by the Traffic source. The Company does not process obtained full IP address of the Third Party or another information about Third Parties.

4.4. The Company processes pseudonimised IP address of the Third Party to determine country where such Third Party is.

4.5. The Company does not collect and/or process the sensitive data.

4.6. The Company does not collect from Data Subjects more personal data than it is determined in this Policy. The Company also does not collect more personal data than it is needed for the purposes of processing specified herein.

4.7. While collecting and processing the Users, Visitors and Partners (or its employees) personal data, the Company acts as the controller thus, the corresponding range of controller rights and responsibilities arises. The Company is not controller or processor of the Third Parties’ personal data.

5. The lawfulness of processing

5.1.The Users personal data are being collected while the appropriate User is registering on the Website.

5.2. The Company processes the Users personal data on the basis of the consent which is provided by User before registration upon to the Consent Form.

5.3. The consent is considered to be provided to after the User has pressed the “I give consent” button in the end of the appropriate User Consent Form through the Website. In the Consent Form the User may not agree with processing his/her personal data for sending him/her most relevant advertising material and offers concerning Services based on the profiling such information about him/her.

5.4. The User confirms that he/she is eighteen (18) years of age or older by putting a tick in front of relevant sentence.

5.5. By giving the consent the User acknowledges and accepts all terms and conditions specified in the Privacy Notice and Consent Form as well as all conditions specified in the current Policy.

5.6. It worth to clarify that the Privacy Notice is to be provided to the Users within the Website right before the appropriate registering form is filled in.

5.7. The Company shall be able to demonstrate that consent was obtained for the processing operation if it is required.

5.8.The Visitors personal data are being collected while the appropriate Visitor is entering the Website. Herewith, the personal data are being collected via a consent. The consent is considered to be provided to after the Visitor has pressed the “I give consent” button in the end of the appropriate Visitor Consent Form through the Website.

5.9. Along with the Consent Form, the Company provides the User and the Visitors with the Privacy Notice, which contains, including the precise information concerning the purposes of processing and the information on methods of processing as well as on the period for which such personal data are to be stored.

5.10. The Company processes Partners (or its employees) and Third Parties’ personal data, because such data processing necessary for the pursuation of the legitimate interests (based on the contracts) of the Company or another person.

6. User age

6.1. The Company collects the personal data on the basis of consent obtained from the Data Subjects who have reached the age of 18 years.

6.2. Registering on the Website and giving the Company the consent, the appropriate User acknowledges that he/she reached the age of 18 years and has all rights to provide to the Company the consent to his/her personal data processing.

6.3. If you know that the Company processes data of person under 18 years old, please inform about this by writing to e-mail address: support@kadam.net.

7. Withdrawing of consent

7.1. The Data Subject is entitled to withdraw the consent at any time he/she wishes. The withdrawal of the consent is considered to be properly made after the Data Subject has sent such letter of withdrawal to the next e-mail address: support@kadam.net.

7.2. The appropriate request for withdrawing of the consent shall be examined within 72 hours since a moment the respective form of withdrawal is received, and the adequate decision will be made by the Company.

7.3. The User is entitled to withdraw the consent at any time in own account at the Website by deleting it. The User can in own account at the Website withdraw the consent for sending most relevant advertising material and offers concerning Services based on the profiling such information about User.

8. The period of storage

8.1. The Company processes and stores the personal data during the period that is needed for realization of the processing purposes, specified in this Policy.

8.2. Taking into account the purposes of processing, the period of storage of the personal data (period of storage) is:

Personal dataPeriod of storage
The Users personal data

- Name

- E-mail address

- Telephone number

- ICQ UIN;

- Skype login

- Telegram number

- IP address

- HTTP cookies

no more than 2 months since User’s last activity at the Website.
The Visitors personal data

- Browser type and version;

- Operation system type and version;

- Information about visited websites;

- Information about advertising materials displayed to the Visitor on the Web-site;

- Clicks on the advertising materials on the Website.

no more than 12 months since date of Visitor consent..
The Partners (or its employees) personal data

- Full name;

- Position;

- АE-mail address;

- Ways of communication

no more than 10 years since the end of agreement with this Partner

8.3. After an expiration of the period of storage, the Company is obliged to delete the personal data or ask the Data Subject to provide the Company with a new consent if the necessity of processing remains actual for the Company or another purpose of processing appears.

8.4. The Company is entitled not to store more and delete the earlier collected Data Subject personal data of at any time if such personal data are not needed more. Herewith, the Company is obligated to notify the respective Data Subject that his/her personal data are deleted.

8.5. The Company may keep storing the personal data if a subsequent processing is foreseen by law and is deemed relevant for a purpose which is not compatible with the original purpose of processing stated in this Policy. Herewith, under the incompatible purposes means the purposes concerning archiving in the public interest, scientific, statistical or historical use.

9. Processors

9.1. While processing the Users personal data, the Company engages processors which act only in accordance with the Company instructions and within appropriate contract concluded between them. Users personal data processors are Partners wich provides support with authorization, account managing, account security, system software errors, Services, bans etc. Partners that get personal data from the Company are located in the Commonwealth of Independent States.

9.2. While processing the other Data Subject’s information, the Company does not engage processors.

9.3. The Company is responsible for the proper processing of the Users’ personal data under the GDPR. Herewith, each processor is responsible for the adherence of the GDPR as well as for other legislative actions concerning data protection while processing the Users’ personal data.

9.4. The processors are not entitled to define any additional purposes for the personal data processing.

9.5. The Company commit ourselves to reducing the data breach risks, so selects Partners with an impeccable reputation and conclude a confidentiality agreements with them.

10. Data subjects rights

10.1. This Policy provide all Data Subjects with opportunity to realize any of the following rights:

right to access. The Data Subjects have a right to know whether their personal data are being processed and if so, access such data.

right to rectification. If the personal data are inaccurate, the respective Data Subject is entitled to ask the Company to correct them indeed.

right to erasure or right to be forgotten. The Data Subjects have a right to obtain from the Company the erasure of the Data subjects’ personal data without undue delay and the Company has the obligation to erase such personal data without undue delay.

right to restriction of processing. The Data Subjects have a right to limit processing of their personal data with several exceptions under the scope of the GDPR.

right to be informed. The Company obliged to inform Data Subjects what data is being collected, how it’s being used, how long it will be kept and whether it will be shared with any third parties. This information must be communicated concisely and in plain language.

right to data portability. The Data Subjects are permitted to obtain and reuse their personal data for their own purposes across different services. This right only applies to personal data that Data Subject has provided to the Company by way of the consent.

right to object. The Data Subjects can object to the processing of personal data that are being processed by the Company. The Company must stop processing personal data unless the Company can demonstrate compelling legitimate grounds for the processing that overrides the interests, rights and freedoms of the individual or if the processing is for the establishment or exercise of defense of legal claims.

right not to be subject to a decision based solely on automated processing. The Data Subjects have a right to object to any automated profiling that is occurring without consent. Herewith, the Data Subjects have a right their personal data are to be processed with the human involvement.

10.2. The User can realize righ to access and right to restriction of processing in own account on the Website. The User has the opportunity at any time withdraw consent to his/her personal data processing for purposes of direct marketing in own account on the Website.

10.3. The User can realize right to erasure by deleting own account on the Website.

10.4. The Data Subject has the opportunity at any time withdraw consent to his/her personal data processing for purposes of displaying to him/her most relevant advertising material and offers concerning Services based on the profiling such information about Data Subject byusing option “Opt-out” at the Website ( https://www.kadam.net/ru/opt-out).

10.5. The Data Subject can realize any of described above rights by sending request to the e-mail address:support@kadam.net. Data Subject request must include name, contact information of the Data Subject, right which Data Subject wants to realize, personal data processed by the Company, details and reason/justification of such request.

10.6. These are the timescales within which the Data Subjects may realize its rights, stated above (the period starts from the moment the Company receives the request):

Data Subject RequestTimescale
The right to be informed When data is collected
The right of access2 weeks
The right to rectification 2 weeks
The right to erasureWithout undue delay
The right to restrict processingWithout undue delay
The right to data portability2 weeks
The right to objectOn receipt of objection
Rights in relation to automated decision making and profiling2 weeks

11. Data Protection officer

11.1. The information about Data protection Officer of the Company is as follows: Dmitry Vasnin ( dpo@kadam.net).

12. Security

12.1. The Company is responsible for ensuring that any personal data that Company holds and for which they are responsible, is kept securely and is not under any conditions disclosed to any persons unless that persons has been specifically authorized by Company to receive that information and has entered into a confidentiality agreement.

12.2. All personal data should be accessible only to those who need to use it.The personal data shall be treated with the highest security and must be kept encrypted.

13. Data breach notification

13.1. The Company takes all reasonable steps to minimize the risk of the personal data breach while processing the personal data.

13.2. In the case of a personal data breach, the Company shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the DPA, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of the Data Subjects.

13.3. The risk assessment the Company has to carry out will have determined whether the risk to the rights and freedoms of the data subjects affected is judged to be sufficiently high to justify notification to them.

13.4. Also, in the case of a personal data breach, which is likely to result in a high risk to the rights and freedoms of the Data Subjects, the Company shall without undue delay notify the appropriate Data Subject the personal data of which were breached.

13.5. If measures have subsequently been taken to mitigate the high risk to the Data Subjects, so that it is no longer likely to happen, then communication to the Data Subject is not required by the GDPR.

13.6. The Company documents all personal data breaches, comprising the facts relating to the personal data breach, its effects and the remedial action taken. That documentation shall enable the DPA to verify compliance with the GDPR.

13.7. The respective processor is obligated without undue delay to notify the Company about the breach of the personal data while processing such personal data under the Company’s instructions.

14. Data transfer

14.1. The Company stores personal data in Karlsruhe, Germany.

14.2. The Company does not sell or trade personal data to any legal persons or individuals.

14.3. The Company may transfer the personal data to its processors, specified in this Policy and which are registered in the Commonwealth of Independent States, it must be understood that the Company transfers the personal data based on GDPR and adequacy decision if needed.

14.4. The personal data are being transferred for the purposes defined.

15. Additional conditions

15.1. A current version of this Policy is available to all subjects concerned on the Website.

15.2. The Company may revise this Policy from time to time. If the Company makes material changes to this Policy, it will notify the Data Subjects by e-mail or by posting a notice on the Website prior to the effective date of the changes. By continuing to access or use the Website after those changes become effective, Users and Visitors agree to the revised Policy.