Servicing Assessment
& Repair Appraisal
& Repair Appraisal
new version, updated 22 of august 2018
This Privacy Policy describes how AVTOPRO (“Company” or “we” hereby) uses and discloses information that is collected by us or provided by you when you visit and/or register on our Site located at https://sara.avto.pro (the “Site”) or use our Platform, Software or Services. This Privacy Policy is part of our Terms of Use located at sara.avto.pro, and in cases some subjects are not highlighted inhere, please, consider provisions of the mentioned Terms of Use.
By accessing the Site or using our Platform, Software or Services, you become subject to this Privacy Policy and voluntarily give us your consent for as well as grand us all rights for processing, collecting, transmitting (to the extent permitted by applicable law or Regulation) and storing of your Personal Data and Non-Personal Data in order to provide you with the most efficient services and user experience, improving of our Software, Platform, Services and Site, track the behavior of users during their use or browsing through our Software, Platform, Services and Site, statistical purposes, providing your Personal Data to our partners and affiliates for the purposes of performing our obligations to you (e.g. Agreements, Insertion Orders etc.) and other purposes pointed herein as well as to the other governmental and non-governmental authorities whenever they have the right to demand disclosure of such information (including Personal Data – if this is permitted and to the extent permitted by applicable law or Regulation), as well as for our use of Cookies. As well, you agree to all the conditions pointed herein and give us your free unambiguous consent to act with your Personal Data as pointed in this Privacy Policy.
We are the sole owners of the information collected on this Site, through the Platform, Software or Services. We only have access to/collect information that you voluntarily give us. Unless you ask us not to, we may contact you via email in the future to tell you about specials, new products or services.
“Cookies” - small files that the Site, web-based software services or service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the Website's or service provider's systems to recognize your browser and capture and remember certain information.
“Personal Data” - data that directly, or when used in conjunction with other provided data, enables the identification of a specific individual.
“Non-Personal Data” – data in a form that does not, on its own, permit direct association with any specific individual.
“Services” – access to some functionality that the user receives when registering on the Platform (for example, billing and SDK, which can be integrated into the mobile application, etc.), or using other products of AVTOPRO.
“Platform” - a software solution owned by us used for managing and serving campaigns, tracking, aggregating statistics, and interacting with clients and affiliates.
“Software” – refer to Platform with all of its functions, other products of AVTOPRO and the Services (as determined above).
“Pseudonymisation” – replacing any identifying characteristics of data with a pseudonym, or, in other words, a value which does not allow the data subject to be directly identified.
“Anonymisation” – processing data with the aim of irreversibly preventing the identification of the individual to whom it relates.
“Regulation” – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation).
“Law” – data protection and other laws and regulations of Ukraine, applicable to the subject matter, and Regulation as determined above.
Contact Information: When you access or otherwise use the Site or register / sign up for the Software, we may collect certain contact information from you, such as your first and last name, company name, city, state and zip code, email address, office and mailing address, phone number, password, skype name, counter-party's names, company website or other contact details to help you with your experience (collectively, "Contact Information"). When using Software and accompanying services, you will be required to provide additional information that may include a credit card number, account number, beneficiary’s name and details, account holder, bank name, pay pal information, pay pal account details or other banking and payment information ("Billing Information"), as well as information necessary to secure your transactions, including the whitelist of IP addresses. This information is required by us to verify your identity, to establish your company’s account, and set up your Services.
Site Information and Cookies: We may use Cookies, web beacons and other technical means to collect and analyze certain information about how you and other visitors use the Site. This technical information includes Internet Protocol (IP) addresses, mobile ID, browser information, and the preceding and succeeding websites you have visited, among other things. We may also keep a record of which pages of the Site you visit, and how long you spend on each page. Cookies can also be used to help us understand your preferences based on previous or current Site and/or Software activity, which enables us to provide you with improved Services. We also use Cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better Site experiences and tools in the future.
You may set your browser to notify you or decline the receipt of Cookies; however, certain features of our Site and Software may not function properly or be available if your browser is configured to disable Cookies and/or other technical means that allow to receive data pointed above.
These technologies help us better understand user behavior, tell us which parts of Site you have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as Non-Personal Data. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Data by law or Regulation, we also treat these identifiers as Personal Data. Similarly, to the extent that Non-Personal Data is combined with Personal Data, we treat the combined information as Personal Data for the purposes of this Privacy Policy and compliance with law and Regulation.
Service Information: In order to provide Services to you and to improve your experience, we may collect information that is created or provided by you in connection with your use of the Services (collectively, “Service Information”), including ticket logs and information about your actions in various client areas on the Site or within the Software. Service Information may include Personal Data. We use Service Information to market our Services to you in a more personalized manner.
Billing information: in order to execute transactions upon providing Services, we can request an information related to your banking or other accounts. The user signing in the Software warrants that he is a legal representative of the business entity and is entitled to provide this kind of information regarding such entity.
In addition to the uses described above, we may use information collected from you when you use Software, register or sign up for the Software, sign up for our newsletter, respond to a survey or to our marketing communication, browse our Software, or use Site or its features in the following ways:
We will use your Contact Information and Billing Information to provide Services, bill you and provide you with access to the Software you have ordered, as well as support services, technical updates or updates on changes in our usage policies. We may also use your Contact Information to send you company updates and marketing offers when permitted by law (Regulation) and/or when you have agreed. You may refuse or revoke your consent to use Personal Data for the above purposes at any time by terminating a subscription and contacting us via the email address provided in this Privacy Policy.
We will store and use Service Information for the purpose of conducting business with you. Use of the Service Information is also governed by the agreements you enter into with us in connection with the Services (Terms and Conditions, Agreements, Insertion orders, etc.). Please refer to the specific Terms and Conditions, Agreements, Data Processing contracts etc. for provisions concerning confidentiality and data protection regarding specific relations appeared out of such agreements (if any). In the event of any conflict between this Policy and the specific Terms and Conditions, Agreements, Data Processing contracts etc., the latest will prevail.
We may use any information collected from you (Personal and Non-Personal Data): (i) to personalize user's experience and to allow us to deliver the type of content and product offerings in which you are most interested; (ii) to improve our Software in order to better serve you and/or to provide Services more effectively; (iii) to ensure continuous improvement and development of the Software; (iv) to administer the Site, the Software and accompanying Services and to diagnose possible problems; (v) to send periodic emails regarding your order or our other products and services.
We may collect, use, transfer, and disclose Non-Personal Data for any purpose pointed in this Privacy Policy. We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where Software is used so that we can better understand customer behavior and improve our products, services, and advertising. If law or Regulation treat all or part of the pointed information as personal, we would treat it the same way.
We may collect information regarding customer activities on our Site and Software and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our Site or Software are of most interest. Aggregated data is considered Non-Personal Data for the purposes of this Privacy Policy as it doesn’t allow to identify specific individual.
We may collect and store details of how you use our Software, including search queries. This information may be used to improve the relevancy of results provided by our Software. Except in limited instances to ensure a quality of our Software over the Internet, such information will not be associated with your IP address.
If we do combine Non-Personal Data with Personal Data the combined information will be treated as Personal Data for as long as it remains combined.
As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit Software, operating system, date/time stamp, and clickstream data. We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. We may use this information in our marketing and advertising services.
In some of our email messages, we use a “click-through URL” linked to content on our Site or Software. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our Site or Software. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
To provide location-based services we may collect, use, and share precise location data, including the real-time geographic location of your access to Site and/or Software. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used to provide and improve location-based products and services. We may be obliged to process such information in order to comply with law or Regulation.
We can collect Personal Data for protection of our users from fraud or other illegal activity which can be fulfilled with unlawful use of your Personal Data on Site and/or Software (as a way of example, we may collect Personal Data to form conversion IP whitelist).
We can provide some of your Personal Data to our partners, contractors, affiliates if it is necessary for performing agreements between you and us (e.g. Agreements, Insertion Orders etc.) or if it is an essential part of how our Software work.
We can delete personal and Non-Personal Data any time we consider it appropriate and in compliance with the purposes we collected it for, unless we are required by law or Regulation to store such information for particular period of time.
We may use third party (processor, contractor, affiliate, partner, contractors, suppliers, vendors etc.) to perform certain business-related functions. Examples of such functions include, but are not limited to: data storage services, database maintenance services, and payment processing. When we use such third party to perform services on our behalf, we will only provide them with access to Personal Data that they need to perform their specific function. We will make sure that each third party will be required by contract to keep such Personal Data confidential, make necessary steps to protect such Personal Data and not to use it for any purpose other than providing services to us and other provisions as required by law and Regulation.
Before transferring any Personal Data to third party (processor, contractor, affiliate, partner, contractors, suppliers, vendors etc.) we shall make reasonable check of such third party regarding its compliance with law and Regulation. We will make commercially reasonable efforts to store Personal Data of individuals in the regions where they live or operate in cases if we are required by law or Regulation to do so (e.g. Personal Data of EU citizens in EU or countries acknowledged by relevant authority as having appropriate level of data protection). If storing of Personal Data in such way is not commercially reasonable, we will ensure that third party processors are bound by agreement which contains obligations of the processor to provide at least minimum necessary level of security and other provisions as required by law or Regulation (e.g. as required by approved model data processing agreements adopted by relevant data protection authority). As well, we will ensure that such agreement contains obligation of processor to adopt necessary provisions into his agreements with sub-processors (if any). Herein you give us your free unambiguous consent to store your Personal Data (and Non-Personal Data, if applicable) outside of your country of residence (registration, domicile, center of vital interests, economic region, etc.).
We may disclose Personal Data if required to do so by law (Regulation) or to comply with a legal obligation, or if we believe in good faith that such action is necessary to: (i) protect our rights or property and our customers or (ii) protect the property or safety of users of the Site or the Software and the accompanying services, legal owners of the Site or the Software; or any third party. If we will be required by law to disclose any of your Personal Data, we will use reasonable efforts to provide you with notice of that disclosure requirement, unless we are prohibited from doing so by statute, court or administrative order.
We reserve the right to sell, assign or transfer our business or assets. In any such event or similar event, including but not limiting to a corporate sale, merger, reorganization, dissolution, etc., Personal Data may be part of the transferred assets. You acknowledge that such transfers may occur and that any acquirer or successor of ours may continue to use your Personal Data as set forth in this Privacy Policy.
Please note that your non-personally identifiable information (Non-Personal Data) may be provided to other parties for marketing, advertising, statistics or other uses. This is not linked to any Personal Data that can identify any individual person.
In order to use Software, a user must first complete the registration form. During registration, a user is required to give certain information as described above in this Privacy Policy. In addition to the purposes pointed above, this information is used to contact you about the products/services on our Site in which you have expressed interest. At your option, you may also provide additional information about yourself, but it is not required.
By refusal to provide data necessary for registration, you refuse to receive our Software and Services.
In case you act as an agent for a third party during registration or use of our Site/Software you should be duly authorized to provide us with necessary amount of the data of such third party. By registering, you represent and warrant that you are duly authorized.
We will maintain industry-standard physical, electronic and procedural safeguards designed to protect data in our possession from loss, misuse, any use not pointed in this Privacy Policy and unauthorized access. Wherever we collect Personal Data, we make all commercially reasonable efforts to provide the necessary level of Encryption/Anonymisation/Pseudonymisation, as required by applicable law or Regulation. We can provide such security measures by using third parties (e.g. processors, contractors etc.).
However, no method of transmission or method of electronic storage is 100% secure. We do not guarantee that our Site or the data stored during your use of the Software is invulnerable to hacking and will not be subject to a security breach. We make no warranty, guarantee, or representation that the Site, the Software or the Services are or will be protected from all viruses, security threats or other vulnerabilities or that your Personal Data and Non-Personal Data will always be secure.
To make sure your Personal Data is secure, we communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the company. Only employees who need your Personal Data to perform a specific job (e.g. billing or customer service) are granted access to relevant personally identifiable information (Personal Data). All of our employees sign relevant NDA and our security system is designed to ensure possibility of identification of all the employees who had access / accessed Personal Data of our users.
Your obligations regarding security of your data are the following: not to disclose your contact information and other data which allows/enables unauthorized access to the Software and/or Site or any other actions connected to the Software and/or Site on your behalf; make reasonable efforts to secure your actions in Internet and your use of the Software. You are solely responsible for the correctness, appropriateness fullness etc. of the provided data and warrant to us that you have all rights to provide us with such data.
In cases if we receive your Personal Data from third party (controller of such data) during fulfillment of contractual obligations, we act as a processor. In order to secure such received Personal Data, we treat it with the same level of security as we treat Personal Data collected by us as pointed in this Privacy Policy (if applicable or if we are not obliged by the relevant contract to provide additional security measures). Notwithstanding anything to the contrary, you should acknowledge that we do not store such Personal Data for period longer, than it is necessary to for fulfillment of the relevant contract with third party who provided us with your Personal Data.
For the convenience of our users and visitors, the Site, Software and/or emails may contain links to other sites, which are subject to different privacy policies. This Privacy Policy will not apply to other sites, software or accompanying services. Please be aware that we are not responsible for the content or privacy practices of such other sites.
Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage our users to be aware when they leave our Site/Software and to read the privacy statements of any other site that collects personally identifiable information (Personal Data).
Our Site and Software include and/or may include social media features and widgets (the “Features”). These Features may collect your IP address, which page you are visiting on our Site, Software and may set Cookies to enable the Feature to function properly. Features are either hosted by a third party or hosted directly on our Site and/or Software. Your interactions with these Features are governed by the privacy policy of the company providing it.
When you use Site, Software, or applications or post on Site or Platform forum, chat room, board, or social networking service, the Personal Data and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the Personal Data you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features. By submitting actions pointed above you grand us, our partners and affiliates a non-exclusive, unlimited, worldwide, royalty-free license to use, display, perform, copy, transmit, distribute, promote, alter, modify, manipulate or create derivative works with materials, texts, words, impressions and other information provided by you in such a way.
From time-to-time, our site requests information via surveys or contests. Participation in these surveys or contests is voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information (such as name and address), demographic information (such as zip code, age level) and business information (types and amounts of Services used, targeting specifications). Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site, and to notify the winners and award prizes (if any).
We understand the importance of taking extra precautions to protect the privacy and safety of children accessing Site and/or Software. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to use Site and/or Software, unless their parent provided verifiable consent or as part of the child account creation process (if this type of account is applicable). If we learn that we have collected the Personal Data of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible, unless we are obliged to keep such data in order to comply with law or Regulation.
If at any time a parent needs to access, correct, or delete such Personal Data he may contact us through email pointed in this Privacy Policy.
Whenever we make an update of this Privacy Policy it will be available on our Site with the mark “new version updated ...”.
You acknowledge and voluntarily agree that we have no obligation of sending you via email or otherwise any notification regarding such change, though we have right to do so if consider it appropriate.
You can access the new version of Privacy Police from the same day as it comes to affect – so you have the time to make a decision regarding the further use of our Site and Software. As well, we can make a draft of new Privacy Policy available in advance if we will consider it appropriate.
You acknowledge that and voluntarily give us the right to change also the purpose of using, collecting and proceeding of your Personal Data and this changes will be pointed in the new version of our Privacy Policy and won’t require any additional approval from you. If you won’t agree to the new purposes of processing, you should contact us via email pointed in this Privacy Policy with the relevant statement and immediately stop using Software and Services.
We store your Personal Data for 3 month and make a revision of it after that period. During such revision, we may either delete all of your Personal Data or keep it collected for the next 3 month if: we are providing you Services; you use Software and Site; we are in the middle of dispute or you are our debtor; such information is still necessary for the purposes we collected it. We can delete your Personal Data any time and not wait for 3 month period to end if purpose we collected it for no longer apply. We make no warranties your Personal Data will be available for any specific period of time (3 month, or less or more etc.). Please consider, that we have no obligations to notify you when deleting your Personal Data and can do it at our sole discretion.
You may opt out of any future contacts from us at any time. You can do the following at any time by contacting us via the email address provided in this Privacy Policy: see what Personal Data we have about you, if any; change/correct any Personal Data we have about you; have us delete (right to be forgotten) or transfer (export) Personal Data we have about you; express any concern you have about our use of your Personal Data (including objecting against the processor); withdraw your consent for our collection, processing and use of your Personal Data; other rights granted to you by current law and Regulation.
You have the right to demand deletion of your Personal Data, right to change or correct it. In order to exercise this right you should send a relevant request via email pointed in this Privacy Policy. We will delete/change/update your Personal Data without undue delay, but in any case within 60 days from the day of receipt of your request. If the Software allows it, you may update, correct, change or delete relevant Personal Data in your personal account at the Site or Software. If you delete or have us to delete your Personal Data (as well as update, correct, change if applicable), we will only retain such copies of the relevant Personal Data as are necessary for us to comply with law and Regulation, governmental and court orders, or to enforce any agreement you have entered into with us.
You have the right to know where your Personal Data is stored and processed (if processed by third party/parties – right to know name and location of the processor/processors). You have the right to object your Personal Data stored or processed by such third party by contacting us via email pointed in this Privacy Policy. As a response to your objection, we may either transfer your Personal Data to other processor (if any and if it is commercially reasonable) or delete it at our sole discretion. You acknowledge that in some cases transfer or deletion of your Personal Data will lead to impossibility of your use of the Software and Services, and our relations will be terminated due to such circumstances. We will transfer your Personal Data to other processor or delete it without undue delay, but in any case within 60 days from the day of receipt of your objection regarding processor.
You have the right to know what Personal Data we have about you, if any. In order to exercise this right you should send relevant request via email pointed in this Privacy Policy. We will solely choose how to provide you such information: written, or by providing access to your Personal Data on our server (other type of storage), or sending it to you by email or on CD/DVD/other device, or in other applicable way, etc. We may decline your request or ask you to pay relevant fees for its fulfillment if your actions has signs of abuse of rights (e.g. you’ve already requested and received your Personal Data last month and there were no material changes in it, yet you request full amount of Personal Data we have about you again). We will reply without undue delay, but in any case within 60 days from the day of receipt of your request.
You have the right to demand transfer (export) of your Personal Data we have, if any. In order to exercise this right you should send relevant request via email pointed in this Privacy Policy. Such transfer (export) should not cause any additional unreasonable efforts for us in order to fulfill it, except as to provide you/requested entity with your Personal Data we have in state (form) we have it (e.g. if you provided and we have it in written, it is unreasonable to ask as have it transferred digitized if we haven’t done it for our purposes already). We will transfer (export) your Personal Data without undue delay, but in any case within 60 days from the day of receipt of your request. We reserve the right at our sole discretion to refuse to transfer (export) your Personal Data or ask for fees if your request causes any additional unreasonable efforts for us in order to fulfill it and your are aware of that.
You have the right to express your concern regarding our data policies. In order to exercise this right you should send relevant request via email pointed in this Privacy Policy. You hereby agree to contact us and explain your concerns so they can be resolved in good faith within 60 days period.
You have the right to withdraw your consent for our collection, processing and use of your Personal Data we have, if any. In order to exercise this right you should send relevant request via email pointed in this Privacy Policy and point regarding which Personal Data (or all of it) and/or which purposes you withdraw your consent. You acknowledge that is some cases withdrawal of your consent will lead to impossibility of your use of the Software and Services, and our relations will be terminated due to such circumstances. We will fulfill your request without undue delay, but in any case within 60 days from the day of receipt of it.
In cases of breach of security which lead to unauthorized access to your Personal Data, we: will let you know about this incident without undue delay as soon as we become aware of such breach and make all reasonable efforts to minimize the harm and restore necessary safety measures. We can notify (inform) you about breach of your Personal Data at our sole discretion in the following ways we consider most appropriate: via your contact email, by phone, in your personal account, in national news, on our Site or any other way which allows you to make necessary steps to minimize the possible harm without undue delay. Such notification will include general information about the breach, possible risks and our steps to minimize them – to the extent possible in relevant circumstances. You are solely responsible to notify your third parties if their Personal Data is part of such breach (if your are the one who provided such information to us). Our notifications shall not constitute our acknowledgment of any kind of fault (guilt, liability) for the breach.
In cases, if you found out that someone illegally provided us with your Personal Data, let us immediately know about this via our contact email pointed in this Privacy Policy. Upon your request, we will delete your Personal Data without undue delay, but in any case within 60 days from the day of receipt of your request. We will only retain such copies of the information as are necessary for us to comply with law and Regulation for such cases.
In order to exercise your rights pointed in this Privacy Policy relevant law and Regulation, you should identify yourself in a way, we can be sure that person who asks for its Personal Data is the one who it appears to be. In cases if you send a relevant request on behalf of company (in cases where Personal Data may be applicable to the company as pointed in law or Regulation), we should be sure you are duly authorized to receive such data about such company. As a way of example, but not limited to: if you send request from the same email you used during registration and with the same signature you usually use in your emails (if there were any between us), we reasonably consider that it is you, who asks for your Personal Data. In cases if you use other email address, or company asks data about itself through other employee (not the one who registered it in our Software) we shall ask for additional verification (unless such additional emails/persons were pointed as trustworthy during registration).
Do Not Track Signals
We do not track you by ourselves over time and across third-party websites to provide targeted advertising and therefore respond to Do Not Track (DNT) signals in a way that we use the usual types of tracking systems that are a standard practice in advertising, e.g. Google AdWords. As well, be aware that some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
We offer interactive Software, which allows you to post content to share publicly or with friends. At any time, you can delete or remove content you have posted using the deletion or removal options within our Software. If you have questions about how to remove content in a specific service or if you would like additional assistance with deletion you can contact us via email pointed in this Privacy Policy. Although we offer deletion capability for Software, you should be aware that the removal of content may not ensure complete or comprehensive removal of that content or information posted through the Software.
You should acknowledge that deleting/stop of use of the Software does not automatically mean that we have no of your Personal Data or that we as well deleted all of your Personal Data we have. In order to have your Personal Data deleted you should contact us via email pointed in this Privacy Policy.
If you have any questions, concerns or complaints regarding the way we collect and handle your Personal Data, or regarding contact person (representative) for compliance with law and Regulation please contact us by av@avto.pro