1. Overview
NETLS (hereinafter referred to as the “NETLS”, “us”, “we”) is an IT company that provides software development and IT consulting services (hereinafter referred to as the "Services") to legal entities and individuals. This Privacy Policy (hereinafter referred to as the “Policy”, “document”) is meant to inform you about the terms and conditions for how we process personal data when you use our Services and the rights you have in connection with such processing with respect to your personal data.
In order to propose our Services and/or render the Services we may ask you to provide us with some information about you that may be qualified as personal data. Your personal data may be collected, specifically, through this web-site, cookies and other means that NETLS may find appropriate and fit for the above mentioned purposes. For the purposes of this Policy any means that we use to collect your data shall fall within the meaning of the term “Services” as defined above.
By providing your personal data to us you simultaneously acknowledge and evidence your consent for NETLS to collect, store and process your personal data.
2. Key terms
User is the individual, who considers using or is using our Services, including but not limited to this web- site visitor.
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession), including but not limited to, email address, phone number, address, etc.
Usage Data is data collected automatically either generated by the use of the Services or from the Service infrastructure itself. Example: IP-address, country.
Cookies are small pieces of data stored on User`s device.
Data Controller means a person, who (either alone or jointly with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.
Data Processor means any person (other than an employee of the Data Controller), who processes the personal data on behalf of the Data Controller in compliance with this Privacy Policy.
Data Subject is any living individual who is the subject of Personal Data.
3. Why we use your data
We may collect and process your information for the following purposes (hereinafter the “Purposes”):
to provide information about our Services for marketing purposes;
to provide access to our services to keep customers involved into project management process;
to provide customer support in order to maintain high level of your satisfaction;
to analyze engagement with our audience or gather valuable information so that we can improve our Services;
to monitor the usage of our Services and improve quality of our Services;
to detect, prevent and address technical issues customers may face during cooperation with us.
4. How your information is collected and used
We may collect different types of your information for the Purposes. Personal Data may be freely provided by you and in case of Usage Data, collected automatically when using this web-site.
All Personal Data that we ask for is critical for us to achieve either of the Purposes. Failure to provide such data may make it impossible for the Services to be properly proposes and/or rendered by NETLS. In cases, when it is specifically stated that some data is not mandatory, Users are free not to provide such data. Non-provision of this data will not result in unavailability or malfunctioning of the Service deliverables.
Users, who are uncertain about which Personal Data is mandatory, are welcome to contact us for clarifications.
4.1. Types of the data we collect
4.1.1. Personal data
For the Purposes we may ask you to provide the following data:
first name and last name;
email address;
phone number;
links to your profiles in social networks;
other Personal Data.
4.1.2. Usage data
We may also collect information how the Service is accessed. This Usage Data may include information such as your computer's Internet Protocol address (IP-address), browser type, browser version, the pages of our Services that you visit or work with, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Information collected automatically through the Services (or third-party services employed in the Services) can also include:
IP-addresses or domain names of the computers utilized by the Users, who use the Services;
URI addresses (Uniform Resource Identifier);
time of a request;
method utilized to submit the request to a server;
size of the file received in response;
numerical code indicating the status of the server's answer (successful outcome, error, etc.);
country of origin;
features of the browser and the operating system utilized by the User;
various time details per visit (e.g., the time spent on each page within the Service) and the details about the path followed within the Service with the special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
4.1.3. Tracking cookies data
We use cookies and similar tracking technologies to track the activity on our Services and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some of our Services.
Examples of Cookies we use:
Session Cookies. We use Session Cookies to operate our Services.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.
We process your Personal Data in a proper manner, and take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Personal Data.
5.1. How we store your data
NETLS will retain your Personal Data only for as long as is necessary for the Purposes. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
NETLS will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services or we are legally obligated to retain this data for longer time periods.
We also take reasonable steps to ensure that your Personal Data that we process is limited to the information reasonably necessary in connection with the Purposes.
5.2. How your data is transferred
Because of the international nature of our business, we may need to transfer your Personal Data to third parties, in connection with the Purposes. For this reason, we may transfer your information to other countries that may have different laws and data protection requirements to those that apply in the country in which you are located.
NETLS will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
NETLS will not transfer your Personal Data to the jurisdictions that do not ensure adequate protection of Personal Data.
5.3. Cases, when your personal data can be disclosed
Under certain circumstances NETLS may be required to disclose your Personal Data. This may happen, if required under the applicable laws or in response to a valid request from public authorities (e.g. a court or a government agency).
Your Personal Data may be used for legal purposes by the Data Controller in court or in the stages leading to possible legal action arising from improper use of this Service, or, the related services. NETLS may disclose your Personal Data in a good faith belief that such action is necessary:
to comply with a legal obligation;
for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
to protect and defend property of NETLS;
to prevent or investigate possible wrongdoing in connection with the Service;
to protect the rights and freedoms of other Users;
in other cases justified by a legally grounded interest.
5.4. Security of your data
We`ve implemented the appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with the applicable laws.
However, we cannot guarantee that there will be no any info breach, and we are not responsible for any breach of security or for the actions of any third parties, when you transfer your Personal Data to us via Internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.
5.5. “Do not track” signals
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
5.6. System logging and maintenance
For operation and maintenance purposes, the Services and any third-party services may collect files that record interaction with the Services (System logs) use other Personal Data (such as the IP Address) for this purpose.
5.7. Links to other sites
Our Services may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
5.8. Children privacy
Our Services are not intended for use by children, individuals who are less than 18 years old.
We do not knowingly collect personally identifiable information from anyone, who is under the age of 18. If you are a parent or guardian and you are aware that your children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers and/or other storages.
5.9. Third party service providers
We may employ third-party companies and individuals to facilitate our Services, to provide the Services on our behalf or to assist us in analyzing how our Services are used.
Third party vendors will only have access to desensitized data within the system to work with, and never have access to Production Environments or "Raw" Data.
5.9.1. Analytics
We may use third-party Service Providers to monitor and analyze the use of our Services.
Google analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Services available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
5.9.2. Behavioral remarketing
NETLS may use remarketing services to advertise on third-party websites to you after you used our Services. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Services.
Google adwords
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
6. Your rights
GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Services. These rights include, in accordance with the applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your personal consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your Personal Data in reliance upon any other available legal bases). Requests should be submitted by contacting us (using the contact instructions below, section 10). If you are an EU resident and have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.
In accordance with the California Online Privacy Protection Act, we may collect Personal Data about your online activities when you use the Services. While we give our users many avenues to opt out of providing Personal Data, we do not respond to Web browsers' "Do Not Track" signals. California's "Shine the Light" law, Civil Code Section 1798.83, permits our users who are California residents to periodically request and obtain certain information about any Personal Data disclosed to third parties for direct marketing purposes. If you are a California resident and wish to make such a request or if you wish for us to refrain from gathering your Personal Data, please submit your request in writing to the contact details mentioned in section 10.
NETLS aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the right:
to access and receive a copy of the Personal Data we hold about you (e.g. in a commonly used electronic format so that you can manage and move it);
to rectify any Personal Data held about you that is inaccurate;
to request the deletion of Personal Data held about you.
Please note that we may ask you to verify your identity before responding to such requests.
7. Information not included in this policy
More details concerning the collection or processing of Personal Data may be requested from us at any time. Please see the contact information in the end of this document.
8. Changes to this privacy policy
We may update our Privacy Policy from time to time. If we believe there is a significant change to this Privacy Policy or our data collection and use practices, we will indicate on our website that our Privacy Policy has changed prior to the change becoming effective.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
9. Legal information
When processing your Personal Data in connection with the Purposes, we may rely on one or more of the following legal grounds, depending on the circumstances:
written consent: we may process your Personal Data where we have obtained your prior, express consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way);
contractual necessity: we may process your Personal Data where the processing is necessary in connection with any contract that you may enter into with us;
compliance with the applicable laws: we may process your Personal Data when the processing is required by the applicable laws;
vital interests: we may process your Personal Data when the processing is necessary to protect the vital interests of any individual;
legitimate interest: we may process your Personal Data when we have a legitimate interest in carrying out the processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies
10. Contact us
contact@netls.com.ua
+38 093 31 05 980