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WINDNFIRE: TERMS OF USE AND PRIVACY POLICY

PRIVACY POLICY

Last update "11" April 2022

The Privacy Policy regulates the procedure for ensuring the privacy of Personal Data.

The provisions of this Privacy Policy describe how WINDNFIRE processes, stores, and collects Personal Data.

We have developed this Privacy Policy to describe how Personal Data is stored and protected.

During the implementation of its activities, the Company may use your Personal Data in various ways, including when providing Services. That is why we have developed this document so that each Client has the opportunity to familiarize himself with the ways in which his Personal Data is used or to decide to refuse such use.

The Company may disseminate Personal Data during its activities. The Privacy Policy describes Third Parties that may receive your data.

References to the words "you," "you," or "yours" (or similar words in meaning) mean our Client, depending on the context of the Privacy Policy.

The provisions of this Privacy Policy apply only to Personal Data obtained by the Company in the ways described in these conditions. WINDNFIRE is in no way responsible for Processing Personal Data by third parties, including a natural or legal entity, who may receive Personal Data under the terms of this Privacy Policy.

During the Processing of the Client's Personal Data, the Company is guided by the General Data Protection Regulation (EU) 2016/679 of April 27, 2016, which is the most common and basic in the world.

We thank you for using the Services of our Company.

1. DEFINITIONS

1.1. Client - an individual or legal entity that interacts with the Company to receive the Services.

1.2. Controller means any natural or legal person, government agency, institution, or other body that independently determines the purposes and means of personal data Processing.

1.3. Cookies are a piece of information in the form of text or binary data is transmitted to the browser from the site.

1.4. Client’s Consent (hereinafter "Consent") means a voluntary, specific, informed, and unequivocal expression of will, in which the Client using a statement or explicit affirmative action agrees to the Processing of his Personal Data.

1.5. Personal Data - means any information that directly or indirectly allows identifying the Client. For example, name, surname, phone number, IP address.

1.6. Processing - means any actions with personal data, including but not limited to: access, provision, distribution, collection, systematization, storage, accumulation, recording, transfer, blocking, deletion, clarification, update and/or change, depersonalization, and other use of personal data, carried out by the Company.

1.7. Processor is a natural or legal person, government agency, institution, or other body that processes Personal Data on behalf of and behalf of the Controller.

1.8. Services - means the promotion of a company and/or a product and/or a page in social networks, complex of actions for using social services as channels for the promotion of a company and/or a product and/or a page and solution of other business tasks, with or without the involvement of third parties.

1.9. Social Network - is a platform, online service and website designed to build, reflect and organize social relationships on the Internet.

1.10. Third Party - means a natural or legal person, government agency, institution, or body other than the Client, Controller, Processor, and persons authorized by the Controller or Processor under their direct supervision to process Personal Data.

1.11. WINDNFIRE (hereinafter referred to as "the Company" or "WINDNFIRE") - is a company on the Internet that provides digital marketing services to the Client.

1.12. WINDNFIRE Site (hereinafter “Site”) - means a web page or group of web pages on the Internet, which are located at: https://windnfire.com/

1.13. WINDNFIRE Application (hereinafter “App”) - is the application of the Company, with the help of which the Client can familiarize himself with and receive the Services of the Company, similar to those indicated on the Site.

2. GENERAL PROVISIONS

2.1. The Company Processes and stores Personal Data based on the principles of legality, fairness and transparency by Article 5 "Principles relating to processing of personal data" of the GDPR.

2.2. The Company acts as a Processor of Personal Data that it receives as a result of providing Services to the Client.

2.3. The Company is not responsible for the Processing of Personal Data by third parties that are not controlled or owned by WINDNFIRE.

2.4. The provisions of this Privacy Policy shall apply only to the Site and/or the App. The Company shall not control and shall not be responsible for any third-party sites to which the Client may access through the links available on the Site.

3. PERSONAL DATA

3.1. The Company receives the following Personal Data about the Client:

3.1.1. full name;

3.1.2. e-mail;

3.1.3. contact phone number;

3.1.4. address: country, city;

3.1.5. region.

3.2. The Client may provide any of his Personal Data when filling in the feedback form ''GET IN TOUCH', in which case the Company Processes such data by the terms of this Privacy Policy.

3.3. The Company can obtain customer data through social networks: Facebook, Instagram and Twitter. In this case, the Personal Data received through Social Networks will be Processed by the terms of this Privacy Policy, but the Company is not responsible for the Processing of Personal Data that the Client places on Social Networks.

3.4. If the Client is a legal entity, the Company has the right to collect and Process statistical data of such Client, namely: name, legal and actual address, bank details, etc. The statistics obtained are stored and Processed in accordance with the terms of this Privacy Policy.

3.5. WINDNFIRE does not collect or Process sensitive Personal Data of Clients, such as race or ethnic origin, political views, religious or philosophical beliefs, union membership, genetic or biometric data, health information, sexual life or sexual orientation.

3.6. The Company collects and uses only Personal Data of users that are necessary for fulfilling their service order, and/or registering on the Site and/or in the App, in order to create an account.

3.7. When you visit the Site or receive the Services, WINDNFIRE may collect the following Personal Data automatically:

3.7.1. IP address;

3.7.2. time zone and language settings;

3.7.3. browser type and version;

3.7.4. operating system, device type and screen extension;

3.7.5. location country;

3.7.6. information about your visit to the Site, including complete details on the URL, route to and from the Site (including date and time), page response time, data loading errors, length of stay on certain pages, activity on the page (such information such as scrolling and mouse movements, clicks), methods used to exit the page, and phone numbers for contacting the service center.

3.8. WINDNFIRE has the right to collect and receive the Personal Data of the Client as follows:

3.8.1. when providing Services;

3.8.2. when placing an order with the Client;

3.8.3. during the Client's description of the his business;

3.8.4. when interacting with employees of the Companies, by exchanging e-mails, messages on social networks and messengers, telephone calls;

3.8.5. use of log files, Cookies and other tracking technologies;

3.8.6. through the use of messengers and social networks;

3.8.7. when using a feedback form;

3.8.8. when signing any documents between the Client and the Company, including but not limited to: agreements, contracts, invoices, etc.

3.9. The Company has the right to use Personal Data for the following purposes:

3.9.1. to provide Services;

3.9.2. to ensure the security of the Site;

3.9.3. contractual relations;

3.9.4. requests and other communications;

3.9.5. for marketing;

3.9.6. to administer the Site and conduct internal operations, including troubleshooting, data analysis, testing and

3.9.7. improve the navigation of the Site based on your preferences;

3.9.8. communication with the Client;

3.9.9. to respond to requests from law enforcement agencies;

3.9.10. to respond to lawsuits, investigate or resolve disputes with the Client.

3.10. The Company may use the Information received from you (for example, your email address) for marketing purposes. For example, by subscribing to our newsletter, you can receive publications and announcements directly to your email. The Company can send you promotional materials about our services, and promotional offers that we think you may be interested in.

3.11. You can unsubscribe from receiving our marketing emails (either in whole or in part) by clicking on the "unsubscribe" link in the emails you receive from us. You may also contact us at any time to cancel your subscription by sending us an email to the email address listed in this Privacy Policy.

3.12. The Company reserves the right to obtain additional information and/or Personal Data of the Client for the provision of Services. If the Client refuses to provide such information or Personal Data, the Company has the right to terminate any relationship with such Client.

4. COOKIES

4.1. Cookie is a small file that is placed on your computer, mobile device or tablet and contains an identification code that allows us to recognize your computer, mobile device or tablet and provide you with the best possible experience on our Site. For example, it allows the Site to remember your actions and preferences (such as login information, language, font size and other display settings) for a certain period of time, so you do not need to re-enter them or re-adjust your preferences every time you return. to the Site or go from one page to another. The use of Cookies is a popular practice for websites and most web browsers allow Cookies by default.

4.2. The pages of the Site may contain electronic images known as Web-beacons (sometimes also called transparent gifs or pixel tags). Web-beacons are usually small images located on a web page or in emails that you view. The request that your internet-connected device makes to download such an image from a server/computer is recorded and it provides us with information such as the IP address of the computer that downloads the image, the time the image was viewed and the type of browser used for this is used.

4.3. The Company uses Cookies for the following purposes:

4.3.1. Client authentication;

4.3.2. storing personal preferences and settings of the Client;

4.3.3. tracking the User's access session;

4.3.4. storing statistics information about the User;

4.3.5. tracking the location of the User.

4.4. When providing the Services, we may use the following types of Cookies:

4.4.1. Session Cookies, also known as transient Cookies, exist only in temporary memory while the Client is on a Site page. Browsers usually remove the session Cookie after the Client closes the browser window.

4.4.2. Persistent Cookies are deleted on a certain date or after a certain period. This means that information about the Cookie will be transmitted to the server every time the Client visits the Site to which these Cookies belong.

4.4.3. Third-party Cookies are a type of files that appears when web pages contain content from external websites, such as links to other websites. For example, they may be used to track the history of Client visits to other websites.

4.4.4. Web analytics Cookies are used to analyze User behavior when browsing various pages of the Site. The use of the above Cookies is based on Article 6 “Lawfulness of processing”GDPR.

4.5. Cookies do not transmit viruses and/or malicious software to your computer, as the data in the Cookie does not change when moved and does not affect the operation of your computer in any way. Instead, they act more like logs (that is, they record user activity and remember state information) and are updated every time you visit Site.

4.6. You may revoke your Consent to the use of Cookies at any time and/or change the categories of Cookies you allow. You may also disable Cookies by changing the settings of your web browser. The information that Cookies collect is in an anonymous form.

4.7. Some Cookies are necessary for the Site to function properly and some are not necessary, but they help us improve the Site. Please note that you automatically accept the necessary Cookies from our Site for its proper functioning when you visit it (unless you have disabled all Cookies in your browser settings).

4.8. We may also use Cookies stored in emails to help us confirm that you have received and responded to such emails.

4.9. Please note that if you disable the use of Cookies in your browser, many functions of the Site will not be available to you. Cookies allow us to track the use of the Site by the Client, measure data and analyze user experience.

5. PERSONAL DATA TRANSFER

5.1. The Company has the right to transfer Personal Data to Third Parties for the implementation and provision of the Services and/or protection of its legal interests:

5.1.1. Contractors and employees. The Company may transfer Personal Data to other entities with which it will cooperate, including legal and tax consultants and entities that provide accounting, marketing and IT services.

5.1.2. Courts, law enforcement, and government agencies. The Company has the right to transfer Personal Data in the event of fulfilling any legal obligations, including in connection with a court ruling.

5.1.3. Third Party. The Company has the right to disclose or transfer the Client's Personal Data during the following transactions: acquisition or merger, financing, corporate reorganization, joint venture, including the sale of assets or in the event of bankruptcy.

6. CLIENT CONSENT

6.1. The following actions of the Client are considered to be the Consent of the Client to the terms of Processing of Personal Data:

6.1.1. filling in the "GET IN TOUCH" form;

6.1.2. conclusion of any contract or other contractual document with the Company.

6.2. The Company reserves the right to obtain the Client's Consent through a pop-up form. The pop-up form may contain the Consent form in the flag submission.

7. PERSONAL DATA STORAGE AND PROTECTION

7.1. The Company uses all necessary security and protection measures for Personal Data to ensure its confidentiality and prevents loss or misrepresentation.

7.2. The Company protects and stores Personal Data from:

7.2.1. losses;

7.2.2. illegal use, transfer, disclosure, alteration, removal and/or destruction.

7.3. We may use the following methods to protect Personal Data in accordance with the article "Security of processing" 32 GDPR:

7.3.1. pseudonymization and encryption of Personal Data;

7.3.2. ability to ensure constant confidentiality, integrity, availability and fault tolerance of Personal Data Processing systems;

7.3.3. regular testing, evaluation and measurement of the effectiveness of technical and organizational measures to ensure the security of processing Personal Data.

7.4. The Company may delete a Client’s Personal Data upon receipt of a request from the Client and upon the termination of the relationship. By deleting Personal Data, we mean deleting all Personal Data from servers and/or written media.

7.5. WINDNFIRE has the right to retain the Personal Data of Clients for 5 (five) years after the termination of the relationship in the following cases:

7.5.1. for statistical accounting;

7.5.2. if the current legislation requires their storage;

7.5.3. if they are necessary for doing business.

7.6. The Company does not store the Client's Personal Data in the event of a request to delete Personal Data on his behalf in accordance with the right to delete, as provided in Article 17 of the "Right to Erase" GDPR.

7.7. WINDNFIRE has the right not to delete Personal Data in the event of a reorganization of the company, the merger of WINDNFIRE with another company, or any other changes in the structure of WINDNFIRE, and in the event of a change of server.

8. BASIS FOR PROCESSING PERSONAL DATA

8.1. The Company collects and Processes Personal Data in accordance with the General Data Protection Regulation.

8.2. The Company Processes Personal Data based on the following legal grounds:

8.2.1. Client's Consent;

8.2.2. Services provision to the Client;

8.2.3. contract conclusion;

8.2.4. to comply with applicable law, for the proper level of our business, to enter into and execute corporate transactions (sale of shares/stocks, mergers, acquisitions), to fulfill its obligations to you and/or a Third Party.

8.3. In cases where the basis for the Processing of Personal Data is your Consent, you have the right to revoke it at any time. In the event of withdrawal of your Consent, the Company has the right to terminate the provision of the Services and terminate all relations with you. If the Consent is revoked, your Personal Data will be permanently deleted.

8.4. The Company undertakes to stop processing Personal Data within 10 (ten) business days from the date of receipt of the withdrawal of the Consent.

9. CLIENTS RIGHTS

9.1. The terms of this section apply to residents of the European Union and the European Economic Area. By the terms of this clause, the Client has the following rights:

9.1.1. Right of access. The Privacy Policy lists the Personal Data of the Client. The Client may contact us directly to request access to the Personal Data we hold about them, as well as to any information in accordance with Article 15 of the General Data Protection Regulations.

9.1.2. Right to erase. The Client has the right to delete Personal Data about himself, in accordance with Article 17 of the General Data Protection Regulations. Personal Data, in this case, will be deleted forever.

9.1.3. Right to rectification. The Client has access to Personal Data, which must be updated, corrected, and supplemented at any time. The Client may also contact the Client support of the Company to access his Personal Data to correct, change, or delete it according to Article 16 of the General Data Protection Regulations.

9.1.4. Right to data portability. We may send the Personal Data Clients to third parties at the request of the Client, in accordance with Article 20 of the General Data Protection Regulations.

9.1.5. Right to object. The Client has the right at any time to object to the Processing of their Personal Data in accordance with Article 21 of the General Data Protection Regulations.

9.2. The Client must provide sufficient information to confirm his identity, whose Personal Data are processed by the Company. If the Client cannot confirm his/her identity, the Company has the right not to fulfill such a request until the confirmation of such identity.

9.3. The Client's request must contain accurate information on the requirements it places on the Company. If the request does not specify the exact requirements, the Company has the right to refuse to fulfill the request.

9.4. We will not be able to respond to your request or provide you with Personal Data unless we are able to verify your identity or authority and confirm that the Personal Data relates to you. In case of receiving a request with inaccurate information and/or in case of impossibility to verify the identity of the Client, the Company has the right not to Process the received request and apply to the Client for clarifications. If a request for clarification is received, the Client is obliged to submit a new corrected request or submit a new request.

9.5. The Company must respond to the request or fulfill the conditions outlined in the request within 21 (twenty-one) business days from the date of receipt.

10. RESPONSIBILITY

10.1. The Company notifies the Client that its Personal Data may be used to provide the Services, and in case of disagreement, the Client must leave the Site and not use the Company Services.

10.2. The Company has the right to collect the Personal Data of the Client to obtain statistical data.

10.3. The Company is not responsible for:

10.3.1. loss of Personal Data in the event of a hacker attack, hacking of the Site software, illegal actions of third parties, illegal actions of the Client and actions that violate the terms of the Privacy Policy;

10.3.2. provision by the Client of inaccurate information and/or Personal Data.

10.4. The Company has the right to refuse the User to provide the Services and Process his Personal Data if he is a resident of a jurisdiction that is prohibited, in accordance with the provisions of the AML/KYC Policy.

10.5. Unfortunately, the transmission of information via the Internet may not be completely secure. Although we make every effort to protect your Personal Data, we cannot guarantee the secure Process of transferring your Personal Data to our Site. In this regard, you are solely responsible for possible failures in sharing your Personal Data with the Site. Upon receipt of your Personal Data, we undertake the necessary technical and security measures to prevent unauthorized access to your Personal Data.

11. ADULT POLICY

11.1. The Company Services are intended for adults Clients. The Company does not process the Personal Data of minors.

11.2. WINDNFIRE has the right to delete the Personal Data of a minor, without warning and any consequences for the Company, and to terminate the provision of such person to the Services.

11.3. If you have information about the use of the Services by a minor, please contact Company support by sending an email to: [email protected].

12. CHANGES TO THE PRIVACY POLICY

12.1. The Company has the right to change the Privacy Policy provisions to ensure the preservation of Personal Data and in case of changes in the legislation governing the Processing of Personal Data.

12.2. The Client is obliged to familiarize himself with the new terms of the Privacy Policy, and the Company is not responsible if the Client has not read the new terms of the Privacy Policy.

12.3. Electronic or otherwise saved copies of the Privacy Policy are considered authentic, complete, valid, and subject to compliance with the versions of the Privacy Policy at the time the Client visits the Site. If the Client uses the Services, then he agrees with the new rules for the processing of Personal Data.

13. CONTACTS

13.1. The Client has the right to contact the support service of the Company at: [email protected] to ensure his rights, by the terms of this Privacy Policy, or in case of violation of his rights, or to leave a response or ask questions.