Privacy Policy

Version 1.0 dated March 15, 2024

• 1.1. This Policy applies to Resetly Pavel Chaus, an individual entrepreneur registered and operating under the laws of the Republic of Poland, with NIP: 583-347-26-59 and REGON: 524657651, address: Gdańsk, Poland (hereinafter referred to as the Company or Resetly) and sets forth procedures for obtaining, processing, and protecting any information, including personal data of individuals (hereinafter referred to as the Personal Data Subject or Subject), within the meaning of applicable law, in connection with:
• 1.1.1. business activities carried out in accordance with the Company's statutory documents aimed at meeting the needs of other persons (hereinafter referred to as the Service);
• 1.1.2. implementation of employment relations;
• 1.1.3. conclusion and execution of contractual obligations, as well as in the course of execution of any agreements and contracts relating to Personal Data Subjects.
• 1.2. The Personal Data Processing Policy (hereinafter referred to as the Policy) is an appendix to the Privacy Policy and applies to any information including personal data of individuals (hereinafter referred to as the Personal Data).
• 1.3. The individual who provided his Personal Data to the Company in the process of receiving the Service and using any websites (hereinafter referred to as the Website), programs, products and/or Internet services (hereinafter referred to as the Services), is a User.
• 1.4. The main categories of processed personal data subjects are specified in Appendix 1.
• 1.5. This Policy shall apply to:
• 1.5.1. Resetly personnel (Resetly personnel shall mean employees under employment contracts and partners providing services to Resetly under civil contracts) (hereinafter referred to as the Personnel);
• 1.5.2. Resetly shareholders;
• 1.5.3. Resetly directors;
• 1.5.4. Services users, Partners, and potential users;
• 1.5.5. Resetly counterparties, if applicable.
• 1.6. The requirements of the Policy shall be taken into account and applied to legal entities:
• 1.6.1. members of the Resetly Group (hereinafter referred to as the Group Companies);
• 1.6.2. other persons when it is necessary for them to participate in the processing of Personal Data (e.g., when data is routinely transferred from Resetly to Group Companies and other counterparties on the basis of orders for the processing of Personal Data, other agreements and contracts).
• 1.7. The list of such legal entities is specified in Appendix No. 2 to this Policy.

• 2.1. The purposes for processing Personal data determine its content and scope.

• 2.2. Resetly shall collect and use Personal data for the following purposes:

• 2.2.1. necessity for our legitimate business interests;

• 2.2.2. contract with Subjects to use the Services as defined in the Articles of Association;

• 2.2.3. ensuring financial and economic activities of the Company;

• 2.2.4. compliance to legal obligations;

• 2.2.5. protection of its legal rights and execution of judicial and/or administrative orders, if necessary.

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2.3. Legal basis for processing personal data

• 2.3.1. The Policy has been developed taking into account the provisions of legislation in the field of Personal Data processing, in particular but not limited to the European General Data Protection Regulation approved by Regulation (EU) 2016/679 of the European Parliament and of the Council dated April 27, 2016 (hereinafter referred to as the GDPR).

• Purposes of Personal Data Processing	Rights and obligations of the Company and the personal data subject
  2.3.2. Fulfillment of contractual obligations	• provision of paid and free services to the personal data subjects;  • exercise and performance of rights and obligations, including for the performance of the contract, a party or beneficiary or guarantor of which is the personal data subject, as well as for the conclusion of the contract at the initiative of the personal data subject or the contract under which the personal data subject will be a beneficiary or guarantor;  • improving the quality of the services provided, as well as related services;  • communicating with Subjects when necessary, including for sending notifications, information and requests related to the provision of Services, as well as for processing applications, requests and other communications received from them.  (1) These notifications include:  • payment information,  • marketing and promotional notifications (mailings) about Resetly's news, products and Services (messages are sent only if the Subject consents to receive them).  (2) At any time on a gratuitous basis the Subject has the right to refuse to receive notifications (mailings) and other information, using a special procedure of refusal of such mailings, if it does not affect the quality of the Services provided.
  2.3.3. Compliance with statutory requirements and obligations	• execution and fulfillment of functions, powers and duties assigned as a processor (operator);  • execution of a judicial act, act of another authority or official to be executed in accordance with the enforcement proceedings;  • fulfillment of orders of other personal data processors.
  2.3.4. Ensuring legitimate interests	• сarrying out activities stipulated by the Company's statutory documents;  • сreation of new products and offers;  • Collecting, processing and presenting statistical data and other research based on impersonal personal data;  • Recruitment (selection of Personnel), including for the purpose of ensuring that candidates for vacant positions are selected for the relevant vacant  • positions, and employment of successful candidates for the relevant vacant positions;  • сonclusion, execution and termination of civil contracts;  • exercising and fulfillment of rights and obligations arising from labor relations, including for the purpose of assisting employees in employment, education and promotion, ensuring their personal safety, monitoring the quantity and quality of work performed and safeguarding property, payment of wages and other payments due to the employee, in accordance with law or contract, as well as making tax and social deductions;  • exercising the rights and legitimate interests as an operator or third parties, including protection against copyright infringement, fraud and other unfair behavior;  • settlements with the personal data subjects.

• Personal Data Processing means any operation or set of operations that is performed on Personal Data or sets of Personal Data, whether or not used by automated means, such as collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, disclosure by transmission, dissemination or other provision, alignment or combination, restriction, depersonalization or destruction.
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• 4.1. Resetly does not verify the Personal Data provided to it, except as provided in contractual or user agreements or in the terms of use of certain Services and cannot judge its accuracy and does not have sufficient legal capacity to provide the Personal Data.
• 4.2. The accuracy of the Personal data and its adequacy and relevance in relation to the purposes of processing shall be ensured if it is necessary to protect the legitimate interests of Resetly. In this case, if inaccurate or incomplete Personal Data is detected, it may be clarified and updated.

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• 5.1. Resetly has the right to make changes at its discretion, including, but not limited to, where the relevant changes relate to changes in applicable law.

• 5.2. This Policy is written in English and Russian. In the event of any discrepancies or any inconsistencies in the meaning of the terms of this Policy, the English version of this Policy shall prevail.

• Unrestricted access to this Policy and its Appendices shall be provided to all interested parties, including Personal Data Subjects and authorities exercising control and supervisory function in the field of Personal Data processing.

If you have any questions, comments or requests regarding this Policy, please contact our Data Protection Officer at support@resetly.io.

1.1 Personal information shall be collected and processed in order to fulfill contractual obligations, as well as the legitimate interests of the Company.

1.1. Competent authorities

• 1.1.1. Upon request, as well as when required by this Policy or applicable law, and only to the extent necessary based on the purpose of the disclosure.
• 1.1.2. To resolve any conflict or dispute arising between the Entities and the Company.
   

1.2. Payment systems and services

• 1.2.1. We transfer and disclose Personal data, including the identity document number and/or date of issue, copies of identity documents (such as a passport) to the following providers of billing and payment services:

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• 1.2.2. We transfer and disclose the Provided Data to the providers of billing and payment services only if they request. If you do not use the providers of billing and payment services on the Platform, we will not share the Provided Data with them.

• 1.2.3. We do not collect or store your credit card information. You provide this information to our providers of billing and payment services. Use of the Provided data for payment processing is governed by their privacy policy.

1.3. Data storage providers

• We store data on our secure servers in EU. The databases are copied to the Amazon Web Services data center (Frankfurt, Germany):