1. Introduction

1.1 SimpITy division of GP Solutions GmbH (further referred to as “we”, “us”, “company”) is committed to safeguarding the privacy of our website visitors. Therefore we prepared this privacy policy to show our website visitors that our company:

– complies with data protection law and follows good practices in the sphere of data protection;

– respects the right to privacy;

– is open about how it stores and processes personal data;

– protects itself from the risks of a data breach.

1.2 This privacy policy applies where we are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.

2. How we collect your personal data

2.1 We collect your personal data when you give it to us directly through filling in any information forms on our website. Please do not supply any other person’s personal data to us.

2.2 Additionally we, like many companies, may use analytics tracking systems (such as Google Analytics, for example) to automatically collect certain information about you when you visit our website.

2.3 We do not knowingly collect personal data from children under the age of 18 without obtaining parental consent. If you are under 18, then please do not use or access our website at any time or in any manner. If we learn that personal data has been collected from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information.

3. How we use your personal data

3.1 In this Section 3 we set out:

– the general categories of personal data that we may process;

– the purposes for which we may process personal data; and

– the legal basis of the processing.

We do not process your personal data in a manner that is incompatible with purposes specified below. We collect personal data with adherence to the principles of data minimization and storage limitation.

3.2 We may process data about your use of our web-site (“usage data“). The usage data may include IP address, browser and operating system being used to connect your computer to the internet, information about pages you visit and how you navigate the website, i.e. length of visits to certain pages, products and services you viewed and searched for, referral sources (e.g. how you arrived at our website), your gender and age, preferences, as well as information about the timing, frequency and pattern of your website use. The source of the usage data is analytics tracking systems that we use (such as Google Analytics). This usage data may be processed for the purposes of analyzing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3 We may process information contained in any enquiry you submit to us regarding our products and / or services (“enquiry data“). The enquiry data may include: your name, your employer name / size / annual revenue, your contact details. The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and / or services to you. The legal basis for this processing is explicit consent, freely given by you.

3.4 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

3.5 We may process any of your personal data identified in this privacy policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.6 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.7 When we legitimately process your personal data, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal data where our interests are overridden by the impact on you, for example, where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).

4. Providing your personal data to others

4.1 We do not sell or rent your personal data to third parties.

4.2 We do not share your personal data with third parties for marketing purposes.

4.3 We may disclose your personal data to any member of our group of companies (this means our subsidiaries and affiliates) insofar as reasonably necessary for the purposes, and on the legal grounds, set out in this privacy policy. Each member of our group of companies will act as processor in relation to any of such personal data that we disclose to it. Information about our group of companies can be found at https://www.simpity.by/contact-us/. By submitting your personal data to us or by letting us to process your usage data, you’re agreeing to this transfer, storing or processing.

4.4 We may disclose your personal data to our third party service providers, suppliers, agents, subcontractors and other associated organizations for the purposes of completing tasks and providing services / selling products to you on our behalf. However, when we use these third parties, we disclose only the personal data that is necessary to deliver the services / sell products and we have a contract in place that requires them to keep your personal data secure and prevents them from using it for their own direct marketing purposes. By submitting your personal data, you’re agreeing to this transfer, storing or processing.

4.5 We may disclose your personal data to our insurers and / or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2 Our group companies have offices and facilities in the Republic of Belarus and the United States of America. You should be aware that these countries may not have similar data protection laws as in EEA. If we transfer your personal data outside of the EEA in this way (which among other may be needed for the performance of a contract between you and us) we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this privacy policy. Transfers to each of these countries, if any, will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

6. Your rights

6.1 You have the right of access, which means that you have the right to know exactly what your personal data is held and how it is processed. Thus, you have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

6.2 You have the right of rectification, which means that you are entitled to have personal data rectified if it is inaccurate or incomplete.

6.3 You have the right to erasure, which means that in some circumstances you have the right to have your personal data deleted or removed without the need for a specific reason as to why you wish to discontinue. Such circumstances include:

– the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; or

– you withdraw consent to consent-based processing; or

– you object to the processing under certain rules of applicable data protection law; or

– the personal data have been unlawfully processed.

Please, pay attention that there are exclusions to the right to erasure. The general exclusions include where processing is necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.

6.4 You have the right to restrict processing, which means that in some circumstances you are entitled to block or suppress processing of your personal data. Such circumstances are:

– you contest the accuracy of the personal data – for a period enabling us to verify the accuracy of the personal data; or

– processing is unlawful but you oppose erasure and request the restriction of personal data use instead; or

– we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims.

Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it with your consent; or for the establishment, exercise or defense of legal claims.

6.5 You have the right to object to our processing of your personal data, if we use personal data for the purpose of direct marketing, scientific and historical research, or for the performance of a task in the public interest. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

6.6 You have the right to data portability, which means that you are entitled to receive the personal data concerning you, which you have provided us, in a structured, commonly used and machine-readable format. You also have the right to transmit this personal data to another controller without hindrance from us, where the processing was based on your consent and where the processing was carried out by automated means.

6.7 If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

6.8 You may exercise any of your rights in relation to your personal data by written notice to us sent by e-mail.

6.9 You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us, then you can inform us about it through e-mail.

7. Retaining and deleting personal data

7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help to ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for the purposes it was collected for.

7.3 We will retain your personal data as follows:

usage data, collected through Google Analytics will be retained for 26 months;

enquiry data will be retained as long as you may be interested in purchasing our relevant products and services. It will be deleted within 3 (three) business days once you explicitly inform us through e-mail that you are no longer interested in our products and / or services and withdraw your consent to processing your enquiry data, without affecting the lawfulness of processing based on consent before its withdrawal;

– customer relationship data will be retained as long as you and your employer continue to be our customer and for a maximum of 10 (ten) years once you stop being our customer. Extra-period for retention is provided in order to keep records of our communications, including, without limitation, for purpose of establishment, exercise or defense of legal claims.

Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

8. Technical aspects

8.1 When you give us personal data, we take steps to ensure that appropriate technical and organizational controls are in place to protect it.

8.2 Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. We cannot ensure or warrant the security of any information you transmit to us. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. As a result, while we strive to protect your personal data, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk.

8.3 We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect personal data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the personal data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public internet.

8.4 However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. If you believe your personal data has been compromised, please contact us.

8.5 If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

8.6 The hosting facilities for our website are situated in Republic of Belarus.

9. Cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

9.2 Before starting to use our website you are informed that we are using cookies. You may agree to such use of cookies. You then may either continue using our website after giving us free consent to do so or you may delete cookies using instructions specified on relevant websites (specified below) and return to use our website when you have deleted cookies and ready to proceed. Thus, you are either using our website with cookies (to which you provided an explicit consent) or without cookies after deleting them from your browser on your own.

We use cookies for the following purposes:

– authentication – we use cookies to identify you when you visit our website and as you navigate our website;

– analysis – we use cookies to help us to analyze the use and performance of our website.

9.3 Our analytics tracking systems use cookies and those cookies may be stored on your computer when you visit our website.

9.4 In case you reject the use of cookies while visiting our website, then you are free to delete cookies. You may do it prior to using our website or at any time after. Most browsers allow you to refuse to accept cookies and to delete cookies:

https://support.google.com/chrome/answer/95647?hl=en (Chrome);

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

http://www.opera.com/help/tutorials/security/cookies/ (Opera);

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

https://support.apple.com/kb/PH21411 (Safari); and

https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

Blocking all cookies may have a negative impact upon the usability of our website.

9.5 We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

10. Other information

10.1 We may update this privacy policy from time to time by publishing a new version on our website.

10.2 You should check this page occasionally to ensure you are happy with any changes to this privacy policy.

10.3 We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your personal data may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified via email and / or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

11. Our details

11.1 This website is owned and operated by GP Solutions LLC.

11.2 We are registered in Republic of Belarus and our registered office is at Zheleznodorozhnaya str., 33A,
Minsk.

11.3 You can contact us by email info@simpity.by.