PRIVACY POLICY

Last updated January 11, 2021



Thank you for choosing to be part of our community at AGROMART, LLC (“we”, “us”, or “our”). AGROMART, LLC is the legal entity which determines the purposes and the means of the processing of your personal data (“controller”). AGROMART, LLC is the legal entity incorporated in accordance with the laws of the Republic of Belarus. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at support@agromartdev.com. 


When you visit our mobile application, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. This Privacy Policy applies only to the practices of companies we own, control, or are united with under common control. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Apps and our services.


This privacy policy applies to all information collected through our mobile application, ("Apps"), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Sites").


Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.



TABLE OF CONTENTS


















Personal information you disclose to us


In Short: We collect some personal information that you provide to us (for example, name, contact information, security data, and social media login data).


We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services, when participating in activities on the Apps or otherwise contacting us.


The personal information that we collect depends on the context of your interactions with us and the Apps, the choices you make and the products and features you use. The personal information we collect can include the following:


Registration Data or Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data, if you register for an account with the Service, or if you correspond with us (in which case we will also retain our responses).


Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.


Social Media Login Data. In some of our apps, we can provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.


All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.


Information automatically collected


In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Apps.


We automatically collect certain information when you visit, use or navigate the Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Apps and other technical information. This information is primarily needed to maintain the security and operation of our Apps, and for our internal analytics and reporting purposes.

Information collected through our Apps


In Short: We may collect information regarding your geo-location, mobile device, push notifications, when you use our apps.


If you use our Apps, we may also collect the following information:


Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.


Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s bluetooth, calendar, camera, contacts, microphone, reminders, sensors, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.


Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.


Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

Analytics information. We may directly collect analytics data, or use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser as part of a web page request, including the web pages you visit, your browser add-ons, your browser’s width and height, and other information that assists us in improving the Service. We may collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.

Software development kits (“SDKs”). We use SDKs to incorporate third party computer code into our app, which allows us, and our business partners, service providers and advertising partners to collect data directly from the app for various purposes, including to understand and improve the Service, monitor and provide support for the Service, provide us with analytics regarding the use of the app, enable interaction with social media platforms, add features or functionality to our app, or facilitate online advertising on other websites or services.

Ads. We may permit third party online advertising networks to collect information about your use of our website over time so that they may play or display ads that may be relevant to your interests on other websites or services. This Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers.


Information collected from other sources


In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.


We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).



In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.


We use personal information collected via our Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.


We use the information we collect or receive:


To facilitate account creation and logon process.If you choose to link your account with us to a third party account *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS" for further information.



To post testimonials. We post testimonials on our Apps that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial please contact us support@agromartdev.com and be sure to include your name, testimonial location, and contact information.


Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.


For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Apps, products, services, marketing and your experience.


In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.


We may process or share data based on the following legal basis:

•Account setup and administration: the legal basis for this processing is Art. 6(1)(b) GDPR.

•Personalization: the legal basis for this processing is your consent according to Art. 6(1)(a) GDPR.

•Marketing and events: the legal basis for this processing is Art. 6(1)(f) GDPR.

•Communication: the legal basis for this processing is Art. 6(1)(b) or (f) GDPR.

•Research and development: the legal basis for this processing is Art. 6(1)(f) GDPR.

•Legal obligations: the legal basis for this processing is Art. 6(1)(c) GDPR or Art. 6(1)(f) GDPR.



Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.


Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

 Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.


Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).


Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.


More specifically, we may need to process your data or share your personal information in the following situations:


Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Apps, which will enable them to collect data about how you interact with the Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.


Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.


Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Apps) or otherwise interact with public areas of the Apps, such personal information may be viewed by all users and may be publicly distributed outside the Apps in perpetuity. If you interact with other users of our Apps and register through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Apps, and view your profile.




In Short: We may only share information with the following third parties.


We may only share and disclose your information with the following third parties - . We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.


Processor

Purpose 

Policy and opt-out

Ad Partners: usually collect data via their own tools (Software Development Kits or “SDK”)

Aarki, Inc.

Advertising service. Personal Data collected: Cookies and Usage Data.

You may opt-out of certain features through your mobile device settings, such as your device advertising settings or by following the instructions provided in their Privacy Policy. You may visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the EU) to learn more about interest-based advertising and how to opt-out of this form of advertising on your web browser by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program.

http://corp.aarki.com/privacy

AppLovin Corp


https://www.applovin.com/privacy/

AdColony, Inc


https://www.adcolony.com/privacy-policy/

ArabyAds FZ LLC (AdFalcon)


http://adfalcon.com/en/

Chartboost, Inc.


https://answers.chartboost.com/en-us/articles/200780269

Fyber N.V


https://www.fyber.com/privacy-policy/

IronSource Mobile Ltd.


https://ironsource.mobi/privacypolicy.html

Index Exchange, Inc.


https://www.indexexchange.com/privacy/

F@N Comamunications, Inc. (Nend)


https://www.fancs.com/en/privacy

OpenX Software Ltd.


https://www.openx.com/legal/privacy-policy/

Rubicon Project


https://rubiconproject.com/rubicon-project-advertising-technology-privacy-policy/

Smaato, Inc.


https://www.smaato.com

Unity Technologies


https://unity3d.com/legal/privacy-policy

UnrulyX


https://unruly.co/legal/privacy/

Snap Inc.


https://www.snap.com/en-US/privacy/privacy-policy/

Tapjoy inc.


https://www.tapjoy.com/legal/players/privacy-policy/

TripleLift


https://triplelift.com/privacy/

Twitter, Inc. (MoPub)


https://www.mopub.com/en/legal/privacy

Verizon Media (Flurry)


https://www.verizonmedia.com/policies/us/en/verizonmedia/privacy/index.html

Zucks, Inc.


https://zucks.co.jp/en/privacy/

AppsFlyer, Ltd. https://www.appsflyer.com/we-are-appsflyer/ and its integrated partners https://www.appsflyer.com/partners/

AppsFlyer, a mobile marketing platform, helps App-Developers, Brands and Ad-Agencies attribute installs to campaigns and optimize their users’ acquisition funnel. Personal Data collected: Device Info, Identity Data.

https://www.appsflyer.com/privacy-policy/ 

Analytic companies: provide us with tools and technologies that allow us to better understand how users interact with our services, usually collect data via their own SDKs

Adjust GmbH

Mobile attribution and analytics. Personal Data collected: Cookies and Usage Data.

https://www.adjust.com/terms/privacy-policy/

Amplitude, Inc.

Analytics service. Personal Data collected: Cookies and Usage Data.

https://amplitude.com/privacy

Other partners

Apple, Inc.

To collect and process payments for subscription to the App. Personal Data collected: Payment and banking information and Usage Data.

https://support.apple.com/en-us/HT210584

Amazon Web Services, Inc.

Hosting and backend service

Personal Data collected: various types of Data as specified in the privacy policy of the service.

https://aws.amazon.com/privacy/

BunnyWay d.o.o.

CDN Personal Data collected: various types of Data as specified in the privacy policy of the service.

https://bunnycdn.com/privacy

Hetzner Online GmbH

Internet hosting. Personal Data collected: Cookies and Usage Data

https://www.hetzner.com/rechtliches/datenschutz/

Facebook Ireland Ltd.

Our Services measures conversions using visitor action pixels from Facebook. This allows an analysis of the effectiveness of Facebook advertisements for statistical and market research purposes and their future optimization. Facebook Analytics is an analytics tool provided by Facebook, Inc. (US) that may collect or receive information from our Services. You can manage your personalized ad preferences in relation to Facebook directly from your Facebook account. Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

https://www.facebook.com/policy.php

Google Inc.

To collect and process payments for subscription to the App; AdMob Google Inc. is an advertising service. Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

https://policies.google.com/terms?hl=ru , https://firebase.google.com/terms/analytics/




LLC “Agromart” – only for the User-downloaded content and, if such download is possible in the application; registration procedure  and the request for additional information.



In Short: If you choose to register or log in to our apps using a social media account, we may have access to certain information about you.


Our Apps offer you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider . The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public. This information could include, but is not limited to, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. We may use this information to find your contacts on the Service, to let you know what your contacts are doing on the Service, and to let your contacts know what you are doing on the Service.


We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Apps. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to Service. You may also unlink your third party social media account from the Service by adjusting your settings on the third party service.



In Short: We may transfer, store, and process your information in countries other than your own.


Our servers are located in Belarus. If you are accessing our Apps from outside Belarus, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above), in United Kingdom, United States, and other countries.


If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.


In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our apps.


The Apps may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Apps. You should review the policies of such third parties and contact them directly to respond to your questions.



In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.


We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 6 months.


When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


In Short: We aim to protect your personal information through a system of organisational and technical security measures.


We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Apps is at your own risk. You should only access the services within a secure environment.


In Short: We do not knowingly collect data from or market to children under 13 years of age.

We do not knowingly solicit data from children under 13 years of age. By using the Apps, you represent that you are at least 13 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Apps. 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. 


In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.


In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.


In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

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.


If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.


If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm


Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.



In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.


California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Apps, you have the right to request removal of unwanted data that you publicly post on the Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.

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.


In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.


We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.



If you have questions or comments about this policy, you may email us support@agromartdev.com or by post Republic of Belarus, 220075, Minsk, Partizansky Ave., 168/25 room 6



HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

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.