This Policy is an integral part of the User Agreement (“Agreement”) posted and/or available on SmallBiz and other agreements entered into with the User when expressly provided for in their terms. Thus, by entering into the Agreement and the said contracts in the manner set forth therein, including the use of the Application, you accept the terms of this Policy in full.
The ways of processing Personal Information include any action (operation) or combination of actions (operations), including, collection, recording, systematization, storage, clarification (update, change), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction for the purposes set forth in this Policy with or without the use of automated means at the discretion of Habra.
Hereinafter in this Policy, the terms and definitions provided by the Agreement and other agreements concluded with the User shall be used, unless otherwise provided by this Policy or derived from its essence. Otherwise, the term used in this Policy shall be interpreted in accordance with applicable law, customary business practice, or scientific doctrine.
Personal Information in this Policy means:
- Information that the User provides about himself/herself upon registration or authorization, as well as in the process of further use of the Application and/or the Service, including the User’s personal data.
- Data that is transmitted automatically depending on the settings of the User’s software in an impersonal form.
SmallBiz has the right to set requirements for the composition of the User’s Personal Information that must be provided in order to use the Application and the Service based on it. If certain information is not marked as mandatory by SmallBiz, such information may be provided or disclosed by the User at its own discretion.
When registering, the User must provide an account name (login), email address and password.
When registering, SmallBiz creates a unique identifier for each User. User ID is linked to User profile information. In order to conclude Agreements the User may also provide the following personal information about him/herself: name, title and phone number.
Data disclosed by the User to an unspecified circle of people. Using the functionality of the Application, the User may independently, by their own actions, at their own discretion, disclose to an uncertain circle of people (publish in the Application) information of their profile in the Application, which may include personal data, including: last name, first name, middle name, sex, date of birth, city of location, place of work, position, information about themselves in a free form. The information added by the User to their profile becomes available to an unlimited number of people, subject to the profile information display settings in the Service.
SmallBiz does not verify the accuracy of the Personal information provided and the availability of the User’s consent to its processing in accordance with this Policy, assuming that the User acts in good faith, with circumspection and makes all necessary efforts to keep such information up to date and obtain all necessary consents from the subjects of personal data.
SmallBiz collects and stores data on User activity in the Service using log files. In the case of actions performed by an authorized User, such information is linked to the User’s ID.
The composition and conditions for collecting anonymized data using third-party software are determined directly by their rights holders and may include:
- browser data (type, version, cookie);
- operating system data (type, version, screen resolution);
- query data (time, transfer source, IP-address).
- Other impersonal data about the User’s actions in the Application.
SmallBiz is not responsible for the way the User’s Personal information is used by third parties with whom the User interacts within the framework of using the Application and/or Service.
Legal basis for the processing of Personal Information
The legal bases on which SmallBiz uses Personal Information include:
- Processing of Personal Information when the User has provided consent to the processing for one or more specific purposes;
- Processing of Personal Information when it is necessary for the performance of a contract to which the User is a party;
- Processing of Personal Information when it is necessary for the conclusion of a contract with the User;
- Processing of Personal Information as necessary for SmallBiz to perform its obligations under applicable law.
SmallBiz does not knowingly collect personal information from, solicit or allow children under the age of 18 to use the App. Individuals under the age of 18 are not permitted to provide personal information, including name, address, phone number, and email address. If SmallBiz becomes aware that information has been collected from a child under the age of 18, SmallBiz will promptly delete such information. If you believe that we may have received any information from or about a child under the age of 18, please contact us at [email protected].
Purposes of Processing Personal Information
SmallBiz processes, including the collection and storage of the Personal Information that is necessary for the conclusion and execution of contracts with the User, and is made publicly available by the User by filling out the profile and setting the settings in myAlpari.
SmallBiz may use Personal information for the following purposes:
- Performance of obligations under concluded contracts, including providing the User with access to the Application and the Service;
- Requests for providing access to the Service are accepted using the software tools of the Application and email. As part of the functionality of the Service, the Rights Holder shall store, systematize and display the User profiles containing Personal Information in the Application.
- Identification of the User within the framework of performance of obligations under the agreements concluded with the User;
- Personal profile of the User is associated with the login-password and e-mail address of the User.
- Providing technical support in connection with the use of the Application and the Service;
- Appeals to the support service are accepted with the use of software tools of the Application and email.
- Providing communication with the User for the purpose of information service and improving the quality of the Service under the signed
- Agreements, including in the order of notification with the involvement of third parties;
- Communication with the User is carried out through e-mail or by subscriber phone number specified by the User during registration or in the process of using the Application and/or the Service.
Compliance with legal requirements.
As an organizer of information distribution in the Internet, SmallBiz stores information about the facts of reception, transmission, delivery and (or) processing of written text, images, sounds, video or other electronic messages of Internet users and information about these users for one year from the end of such actions.
User’s rights with respect to Personal Information
If provided by applicable law, the User has the right:
- Receive information about the collection and use of their personal data.
- To access and correct their personal data if they are incorrect or incomplete.
- To prohibit the processing of their personal data if their accuracy is disputed, the processing is unlawful, as well as in cases where P&R_one no longer needs the personal data for the purposes for which they were processed by SmallBiz.
- To object to the processing of his/her personal data and to prohibit its processing in cases where SmallBiz has processed it in the performance of tasks in the public interest or in its own legitimate interests, and there is no compelling need to continue such processing.
- To withdraw at any time the consent which the User has given to the processing of his/her personal data. In the event that the User withdraws its consent to the processing of personal data, such withdrawal will not affect the legality of the processing that SmallBiz was carrying out on the basis of such consent prior to its withdrawal.
To request deletion of their personal data when:
- they are no longer relevant to the purposes for which they were collected or processed;
- when consent is withdrawn and SmallBiz has no grounds to continue processing;
- when there are objections to further processing for public benefit or in SmallBiz own legitimate interests and there is no compelling need to continue such processing;
- when personal data was processed unlawfully.
Receive Personal Data in a structured, commonly used, and machine-readable form in order to be able to transfer the data, in cases where SmallBiz processes the personal data provided by automated means.
Storage of Personal Information.
All Personal Information collected shall be stored only for the period necessary to achieve the purposes for which such information was collected, or for the period permitted or required by the provisions of applicable law. SmallBiz periodically reviews its data processing systems to determine whether the purposes for which users’ personal information is collected and processed remain valid. Such determination is based on a number of factors, which include, but are not limited to: whether the User maintains a relationship with SmallBiz, whether SmallBiz has fulfilled the User’s requests (including any additional tasks), whether a contractual relationship exists between the User and SmallBiz, and whether contractual or legal grounds exist for continuing to store the User’s personal data. Based on the results of such verification and notifications received from personal data subjects, SmallBiz will update its systems.
In order to improve the quality of the Service and enable legal protection, SmallBiz shall be entitled to keep log files of actions performed by the User within the framework of using the Application and/or the Service, as well as in connection with the conclusion and performance of the Agreement and other agreements on its part, for 1 (One) year from the date of their execution.
Requirements for the Protection of Personal Information
SmallBiz stores Personal Information and protects it from unauthorized access and distribution in accordance with its internal rules and regulations.
Transfer of Personal information
SmallBiz has the right to transfer Personal information to third parties in the following cases:
- The User has expressed its consent to such actions, including when the User applies the settings of the software used that do not limit the provision of certain information;
- The transfer is necessary as part of the User’s use of the functionality of the Application and/or the specifics of the Service based on it;
- In connection with the transfer of the Application to the possession, use or ownership of such third party, including the assignment of rights under contracts concluded with the User in favor of such third party;
- At the request of a court or other authorized governmental body within the procedure established by law;
- To protect the rights and lawful interests of SmallBiz in connection with the violation of contracts concluded with the User.
Modification and deletion of Personal information
The User has the right to edit at any time the Personal information he/she provided during registration or authorization in his/her myAlpari. Users have the right to delete their own account or exercise the right to withdraw their consent to the processing of their personal information by sending SmallBiz a request to delete their account at [email protected].
This Policy may be changed or terminated unilaterally by SmallBiz without prior notice to the User. A new version of this Policy shall take effect upon its posting on the SmallBiz Website, unless otherwise provided for in the new version of the Policy.