Privacy Policy

PRIVACY NOTICE

This Privacy Notice went into effect on _______, 2023.

This Privacy Notice (hereafter referred to as – ‘Privacy Notice’) explains Our approach to Personal Data collection, storage and use on the Website and on the App, as well as Your rights to Personal Data.

I. DEFINITIONS

1.1. Within the Privacy Notice we refer to the listed below notions and mean by them as defined:

• ‘Website’ – Our website which is available at https://www.monobox.tech/.
• ‘App’ – Our mobile application which is available on Google Play Market or/and Apple App Store under the name ‘Monobox’.
• ‘the Services’ – services provided by Monobox, which are available on the Website or App.
• ‘Monobox’ (also ‘we’, ‘our’, ‘us’) – controller of the user’s personal data.
• ‘User’ (also ‘you’, ‘your’) – any natural person that uses the Website and/or an App.
• ‘Personal data’ – any information relating to the User who can be identified, directly or indirectly, in particular by reference to an identifier.
• ‘processing’ – any act when we collect, store, record, structure, adapt, use, make available, erase, restrict access to your Personal data.
• ‘content’ - any files, documents, data, photos, comments, messages, contacts, and so on you provide us with by uploading to or using our Services.

1.2. All other terms used herein are defined under the General Data Processing Regulation (GDPR).

II. CONTROLLER

2.1. The controller is the entity which determines the purposes and means of the processing of user’s personal data.

2.2. The controller of the user’s personal data is legal entity LLC MONOBOX, registered under the laws of Ukraine, registration number: 45149949, registered office address: Ukraine, 02002, Kyiv, Andriy Abolmasov street, house 7, apartment 446; email: ____.

III. PURPOSES AND BASIS OF THE PROCESSING

3.1. Personal data is any information relating to an identified or identifiable user, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier etc.

3.2. Personal data processed. We collect and process user information such as

• a) account information (first, middle and last name, e-mail address, telephone number, contact and billing address (including country and/or state and national ID number);
• b) payment information (including credit card information, billing details);
• c) your content (files, documents, data, photos, comments, messages, contacts, and so on);
• d) your contacts (identifiers of other users you added to your group chats, you send messages or comments to, and invite to use the Services);
• e) usage information (information related to how you use the Services, including actions you take in your account (like sharing, editing, viewing, creating and moving files or folders or group chats, and sending and receiving electronic signature requests and other transactions);
• f) device information (e.g. IP-address, browser settings, operational system, identifiers associated with your devices and other technical information);
• g) cookies (including analytical, marketing);
• h) content analytics (information on how you interact with the viewed content, such as the date and time you view the content or used the Services, the number of times and length of time you view the content or used the Services, and which portions of the content you view or how you used the Services);
• i) marketing (if you use our Services, we will send you information about upgrades when permissible. Users who receive these marketing materials can opt out at any time. If you don’t want to receive a particular type of marketing material from us, click the ‘unsubscribe’ link in the corresponding emails).

3.3. We may process any other personal data that is provided voluntarily by the user. The user is not obliged to provide personal data by law or under any agreement, however, our Services might not be available or might be impossible to be used without some types of personal data.

3.4. Purposes of the processing. The personal data received are processed for the purposes of:

• a) provision of the Services via website and/or app in a reliable and secure manner;
• b) user registration for use the Services;
• c) to perform support regarding user’s use of the Services;
• d) to provide, improve, and promote our Services, and protect our users.
• e) researching the behavior and use of the website and/or app by the user, saving and adjusting the information on the website and/or app according to your preferences, studying the effectiveness of the website and/or app.

3.5. Legal basis for the processing. The legal basis for the processing is:

• a) performance of a contract to which the user is a party or in order to take steps at the request of the user prior to entering into a contract;
• b) legitimate interests and business needs to improve our website and/or app, make the website and/or app usable by enabling basic functions;
• c) user’s consent to the processing for purposes of collecting statistics, storing preferences, tracking visitors use of the website and/or app and display relevant advertisements.

3.6. Retention period. We retains and processes user’s personal data as long as it is necessary to fulfill the purposes defined and the basis of the processing activity exists plus three years, if longer term is not stipulated by the law, or until a request to delete the personal data is received. We will also retain and use your data for as long as necessary to resolve disputes and/or enforce our rights and agreements.

3.7. Child privacy. We neither solicit nor collect personal data from anyone under the age of 16 (sixteen) or under the legal age of your country if it is different unless under the agreement of parents or lawful guardians. If you are a parent or a legal guardian of an underage child, and you know that the child has provided us with their personal information without your consent, please contact us on: [insert email]. It is forbidden to enter personal data of underage users without the agreement of parents or lawful guardians.

IV. USE OF COOKIES

4.1. On the website we use several types of cookies files based on the purpose they are used for (necessary, preference, statistic, marketing and other types of cookies). Cookies are small text files placed on your computer when you visit the website. We use cookie files for the correct display of the website’s content and for the convenience of browsing the website. Cookie files help the website to remember information about you, which will be useful in the next visit. Thanks to cookie files, the website’s browsing becomes much more convenient. You can learn more about these files in our Cookies Policy . You can set up cookies reception and blocking in your browser yourself. Inability to receive cookie files may limit the functionality of the website.

V. PROCESSING OF PERSONAL DATA

5.1. Your personal data is collected, when you consciously provide it to the website and/or app (e.g. when completing an online form, uploading the content) or we collect it by observation (e.g. using automated data capturing software). We do not collect personal data from publicly accessible sources.

5.2. We are processing user’s personal data by automated means. The personal data is kept in electronic form on the website, on app, and on computers, access to which only authorized our employees and contractors has.

5.3. Automated decision-making. Your personal data is not subject for automated decision-making, including profiling. However, third-party cookies are used for analyses of your interests (advertisement preferences).

5.4. Secure. We have a team dedicated to keeping your information secure and testing for vulnerabilities. The data we receive, shall be accessed by our authorized employees only. We continue to work on features to keep your information safe in addition to things like two-factor authentication, encryption of files. We regularly reviewing our data collection, storage, and processing practices, including our physical security measures, to prevent unauthorized access to our systems.

The data center provides customers with direct access to the main Internet traffic exchange points in Frankfurt - DE CIX and ECIX. It ensures secure, high-quality connections with ultra-low latency - between the cloud and network providers, digital media companies, and enterprises. The data center certifications include ISO 27001, ISO 140001:2004, ISO 50001, ISO 9001:2008, PCI DSS, and OHSAS 18001. The data center offers a reliable environment for hosting equipment and adheres to the most stringent industry requirements as per the Uptime Institute Tier IV standard. The Building Management Systems (BMS) facilitates control over electronic, mechanical systems, fire extinguishing, and error detection systems. Physical security encompasses a contactless access card system and 24x7 security staff. Electronic security systems in place include card readers, RFID cards, PIN code + card readers, video surveillance, and motion detection sensors.

5.5. Data storage. To provide you with the Services, we may store, process, and transmit data in locations around the world, including those outside your country. Data may also be stored locally on the devices you use to access the Services.

5.6. Our website may contain links to other websites, which are not under our control. We are not responsible for the content and/or processing of personal data of these websites. We recommend you familiarize yourself with the privacy notice of every website that you visit, if such notice exists.

VI. PERSONAL DATA TRANSFER

6.1. Recipients. Your personal data may be transferred to such categories of processors (subprocessors):

• a) our contractors and subcontractors (marketing manager, IT specialist, customer support manager, administrator etc.), those operating within the jurisdiction outside the European Economic Area, particularly in Ukraine;
• b) hosting providers;
• c) other users you interact with in your group chats, you send messages or comments to, you share files, folders and archives with, and invite to use the Services;
• d) third parties that perform data collecting, independent from us, including Google Analytics, Google AdSense.

6.2. Those processors perform tasks on our behalf and are contractually obliged not to disclose or use collected information for any other purposes, other than specified in this Privacy Notice.

6.3. We do not pass any personal data to other organizations or services, which are not listed in this Privacy Notice. As an exception, the collected data may be provided on a lawful request of state authorities, that are authorized to request such information.

6.4. International transfer. In case, where your personal data is transferred outside the EEA, We enforces the appropriate legal documents that ensure the safeguard of personal data, particularly, the Standard Contractual Clauses.

VII. USER RIGHTS

7.1. User has the right:

• a) to access. You are entitled to see the personal data held about you. You have the right to request a copy of the personal data that we hold about you.
• b) to rectification. If your personal data is inaccurate, you have the right to have the data changed. We encourage you to contact us to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.
• c) to objection. In certain circumstances, you also have the right to object to processing of your personal data and to ask us to block, erase and restrict your personal data.
• d) to data portability. You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format.
• e) to erasure. You have the right to ask or require us to erase your personal data when the personal data is no longer necessary for the purposes for which it was collected, or when, among other things, your personal data have been unlawfully processed.
• f) to restriction. You can limit the way we use your data. This is an alternative to requesting the erasure of your data.
• g) to withdraw consent. When we rely on your consent for the processing of your personal data (particularly, when cookies are processed), you have the right to withdraw your consent at any time (e.g. by deleting or blocking cookies). However, the withdrawal of your consent will not affect the lawfulness of the Our processing based on consent acting prior to the withdrawal.
• h) to file complaints. If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy through the courts.

7.2. You may, at any time, exercise any of the above rights, by contacting [insert email] together with a proof of your identity.

8. INCIDENTS NOTIFICATION

8.1. If we become aware of any breach of our security leading to the accidental or unlawful destruction, loss, alteration or unauthorized disclosure of, or access to (excluding unsuccessful attempts or activities) personal data of user on systems managed or otherwise controlled by us, we will notify you promptly and without undue delay and in compliance to the procedure prescribed under respective the GDPR and applicable laws.

8.2. The notification will be made to your email address. It is the sole responsibility of the user to provide us with the email address and ensure that this email address is valid and current.

8.3. None of the data incidents notification from us may not be and will not be construed as an acknowledgment of any fault or liability with respect to data incidents by us.

9. OTHER PROVISIONS

9.1. This Privacy Notice may be updated in the future to comply with national and international laws regulating the protection of personal data and and will post the most current version on our website. If a revision meaningfully reduces your rights, we will notify you. If your personal data, and more specifically, your contact information was entered incorrectly, we will not be able to contact you.

9.2. If you require any additional information or have any further questions concerning this Privacy Notice, please contact us at [insert email] or by filling a contact form specified in a corresponding section of our website.

9.3. If you do not agree with this Privacy Notice, you cannot use the Services. In this case you should avoid visiting our website and app.