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Privacy Policy
WE REQUIRE INDIVIDUALS WHO HAVE NOT REACHED THE AGE OF 18 (I.E., ADULTHOOD) TO CEASE USING OUR WEBSITE. ADDITIONALLY, IF THE LOCAL LEGISLATION OF THE COUNTRY WHERE YOU ARE A RESIDENT IMPOSES A HIGHER AGE REQUIREMENT FOR USING OUR SERVICES, THAT HIGHER AGE REQUIREMENT SHALL APPLY. BY PROVIDING YOUR PERSONAL INFORMATION TO RINGOSTAT, THROUGH THE SERVICE, YOU REPRESENT THAT YOU ARE AT LEAST 18 YEARS OF AGE OR OLDER.
what is it about?

This is our primary document that outlines the procedures and processes by which we collect and process personal data of our users. This document contains a description of the procedures carried out by us relating to the personal data of our users, and also informs them of their rights concerning their personal data.

The terms of this Policy apply to all users.

The Policy incorporates three additional documents that are an integral part thereof:

  • Data Processing Agreement - the terms of this document apply to registered users.
  • Subprocessor List - the terms of this document apply to all users (regardless of whether they are registered and have an account in the service or not).
  • Tracking technology Policy - the terms of this document apply to all users (regardless of whether they are registered and have an account in the service or not).

We kindly request that you familiarize yourself with all the specified documents, as their provisions directly affect your personal data.

If any provision of the specified documents:

  • is unclear or raises questions for you, we kindly ask you to contact us for clarification via our email. We will explain the meaning of such provision(s).
  • is not suitable for you or you disagree with certain provision(s), we kindly ask you to refrain from using our website and the service "RINGOSTAT".
1. APPLICABLE TERMS

1.1. "We" refers to Netpeak LTD, a limited liability company with its principal place of business at 41 Devonshire Street, Ground Floor, London, United Kingdom, W1G 7AJ.

1.2. "Service" refers to the intellectual property rights object, specifically the computer program (software product) called "RINGOSTAT," which users can access via the internet at the website: https://ringostat.com.

1.3. "You" refers to each of our users.

1.4. "Contract" refers to the Terms of use placed at the following link: https://ringostat.com/terms-of-use/

1.5. “Policy” refers to this Privacy Policy.

1.6. “Visitor” - refers to you as a person who visited the website but does not have or did not register an account. From the moment of registration, the terms of our Data Processing Agreement apply to you instead of the certain provisions of this policy.

1.7. "Account" refers to the tool that provides access to the Service via the internet. It contains information about the user, their means of access, identification, authentication, authorization procedures, account identifier, statistical data, and other information regarding Service usage and your actions. It also contains a virtual section of our website where you can configure, manage, and control the Service, select functionality, create and modify project settings, access usage statistics, and more.

1.8. "Website" encompasses any information resource on the Internet, consisting of a specific number of web pages, each with its own content and Internet address, and which is freely or conditionally accessible to users under a particular domain name.

1.9. "Information about you" includes data pertaining to: a) the email address; b) phone number that belong to you (which we can obtain from you through the module “Contact us” or via email); c) cookies; d) online identifier of messengers (Telegram, Viber, Messenger) which might be obtained by us through the module “Contact us” if you fill the relevant boxes or via email and any other data that you may disclose to us during your use of the Service (for example, through communication with our technical support service.

* The "Contact Us" module is located in the bottom right corner of our website screen. The mentioned module will be unavailable for use if the "Preferences" cookies are disabled.

1.10. "Our email" refers to a specially created email address by us: [email protected], used for communication with data subjects regarding the collection and processing of their personal data, including processing instructions regarding personal data.

1.11. The terms: "Personal data", "Sensitive data", "Controller", "Processor", "Processing", "Data subjectconsent", "Data subject" and "Personal data breach" carry the meanings as defined by the General Data Protection Regulation, available at the following link: https://eur-lex.europa.eu/eli/reg/2016/679/oj

2. OUR ROLES

2.1. We are the controller and the visitor is the data subject.
When using our website without registration:

  • The visitor acts as the data subject, as you share information about you with us.
  • We act as the Controller, as we independently or jointly with others determine the purposes and means of processing personal data of our visitors.

After registering on our website (creating an Account and authorization in it), our relationship regarding the processing of personal data is also governed in accordance with the Data Processing Agreement (DPA).

3. PURPOSES OF PROCESSING

3.1. The purposes of processing Information about you. The processing of such information serves the following purposes:

  • Account registration in the Service
  • marketing and communication with you;
  • compliance with legal requirements;
  • ensuring and/or enhancing the level of security of the Service;
  • investigating fraud, spam, improper or illegal use of the Service;
  • improvement of the Service as a product;
  • other purposes expressly provided for by current legislation or a requirement of a governmental authority.

We acknowledge that any purposes not explicitly stated in this paragraph are limited to our own use.

4. BASIS OF PROCESSING

4.1. The legal basis for processing of Information about you.

If you are the visitor.

  • Cookies. We rely on visitor`s consent to the processing of his or her personal data for one or more specific purposes stated in Section 3.1. of this Policy. Such consent is given by the visitor via “Cookie consent” box on the terms of this Policy and the Tracking Technologies Policy;
  • Any other personal data. We also rely on Legitimate Interest as a legal basis for the lawful processing of personal data. This processing basis applies when we directly receive the visitor's personal data from them via email or our support chat / “Contact us” module (which will not be available if you disable the "Preferences" setting in the cookie consent box). The legitimate interest lies in assisting you in resolving issues related to the use of the Website and/or Service or any other matter you may contact us for.

If you are not the visitor.

All other legal bases for processing personal data of our users are determined by the Data Processing Agreement (DPA) and are used in cases where the user registers and uses an account.

5. CATEGORIES OF PERSONAL DATA

5.1. Categories of visitor`s personal data. We collect and process the following categories of visitor`s personal data

  • Identity Data (via Cookies): includes visitor`s location, preferences, IP addresses, device information, browsing history and activity on a website.
  • Contact Data (via Email / "Contact us" module / Support chat ("Contact support" button): This category comprises email addresses, phone numbers, messenger identifiers (Telegram, Viber, Messenger), and/or any other information that you may directly provide us through the aforementioned communication channels.
  • Personal Preferences (via Cookies): This category encompasses personal preferences, interests, and characteristics, such as language preferences and marketing preferences.

5.2. All other categories of personal data of our users are determined by the Data Processing Agreement (DPA) and are used in cases where the user registers and uses an account.

6. PROCESSINg

6.1. Our processing of visitor`s Personal Data. We process such information based on the following principles and grounds:

  • Lawfulness, fairness, and transparency: We process information about you based on your consent (Clause 4.1 a of the Policy) or based on our legitimate interest (Clause 4.1. b of the Policy), and this process is open and transparent. You can withdraw your consent and/or you may restrict our legitimate interest if you do not wish your data to be processed by us in such a manner, at any time by sending us a corresponding message to Our email;
  • Purpose limitation: We receive and process data solely for the purposes stated in Clause 3.1 of the Policy;
  • Data minimization: We receive and process only the amount of data (Clause 5.1 and 5.2 of the Policy) necessary to achieve our defined purposes;
  • Accuracy: We enable you to maintain the accuracy of your personal data and will update them when necessary. You can do this yourself in your Account or provide us with instructions by sending them to Our email;
  • Storage limitation: We retain the received personal data only for the necessary period to achieve the defined purposes. Data retention periods are established in Clause 6.9 of the Policy;
  • Integrity and confidentiality: We ensure an appropriate level of protection for the personal data we receive, safeguarding them against unauthorized access, loss, or damage (Section 8 of the Policy).
  • Accountability: We are responsible for complying with the terms of the Policy, ensuring proper processing of personal data, and ensuring our activities align with the requirements of the GDPR.

6.2. Other grounds and principles of processing of personal data of our users are determined by the Data Processing Agreement (DPA) and are used in cases where the user registers and uses an account.

6.3. Your instructions. We process Your information based on your instructions. Your instructions encompass the actions and settings performed within the Website, as well as the instructions sent directly to us via email and/or call and/or “Contact us” module and/or support chat.

6.4. However, if we are unable to fulfill any of your instructions regarding the processing of personal data at any point during our cooperation, we will notify you of the impossibility and may refuse further use of the personal data received from you. In such cases, we will delete all personal data received from you, and you acknowledge that our actions cannot be considered a violation of your rights and/or interests or cause harm.

For example. You have contacted us through the "contact us" module with a question regarding the use of one of the features of our product. For communication purposes, you provided the email address [email protected] and requested a response to be sent to that address. After we sent a reply to the email address you provided, we received a message (for example, from the same email address or through the "contact us" module) requesting an explanation regarding:

  • how we obtained this email address;
  • why we are sending messages to it,
  • why we are processing it (email as a personal data),
  • to delete the email from all our databases (right to be forgotten).

Since we cannot independently verify whether the email address belongs to you or another person (the party who sent us the aforementioned requests), we are obliged to comply with the demands of the party contacting us and delete the corresponding data from our servers.

Our actions in this matter are justified by the balance of interests between the individual who may actually own the specified email address, your interest in communicating with us or receiving subsequent consultations regarding the capabilities of our product, and the interests of the individual who does not actually own the email address (if the party who sent us the specified requests has no association with the email address). In our view, the right to erasure (as well as other rights provided by the Regulation) of the individual who may genuinely own the email address prevails over the interests of other individuals in such situations.

In all similar cases (i.e., when we receive instructions from a third party regarding their personal data and cannot verify the identity of the data subject), we will consider the individual making such request to be the data subject, and therefore, we will prioritize the execution of such instructions.

6.5. Your obligation. As you are the controller of Your information, we require you to comply with the obligations set forth by the Regulation, the local legislation of your country of residence, or the legislation applicable to each of your users. Specifically, you are expected to respect the rights, such as the right to be forgotten, of each data subject who is your user or whose personal data you provide to us.

6.5. Data providing and control. You provide us with data through the functionalities of the Website while you using it or by chatting with us. It is within your discretion to determine the extent of data you transmit to us. Furthermore, you have autonomous control over all your personal data, including Your information and Information about you, through the your account of the Service.

Prior to registering an account, the Visitor independently chooses the amount of information they wish to provide to us. Specifically, the Visitor has the option to limit the transfer of any of their personal data to us if they do not select the appropriate settings in the cookie banner.

6.7. Sub-processing. The parties mutually agree and acknowledge that we are authorized to transfer Your information and the Information about you to our sub-processors, as specified and in accordance with our Sub-processor List, which is accessible at the following link: https://ringostat.com/subprocessor-list/.

6.8. Data sharing. Regardless of your user status (visitor or account holder), if you are a resident of a third country and transfer any personal information to us or engage in cross-border transfer of personal data, we will be governed by, apply, and consider the Standard Contractual Clauses to be concluded between you and us.

6.9. Our warranties. We also guarantee and commit to:

  • complying with GDPR requirements and notifying you in case of any non-compliance.
  • never sell your personal data or disclose it to any other persons or in any manner not outlined in the Policy.

6.10. Automated Decision-Making. We do not use Automated Decision-Making technologies and/or algorithms in our Service and Website.

6.11. Processing Period. The commencement of the processing period of your personal data shall be the day on which you accepted the terms of this Policy. The termination of the processing period for personal data, depending on the circumstances, shall be:

  • The last calendar day of the fifth year from the day you last used our Service, or
  • The day you withdraw your consent for the processing of personal data.

6.12. Usage. When you visit our Website we store the name of your internet service provider, the website from which you visited us from, the parts of our Website you visit, the date and duration of your visit, and information from the device (device type, operating system, screen resolution, language, country you are located in, and web browser type) you used during your visit, visited pages, your GA ClientID, your IP address. We use your IP address and/or country preference in order to approximate your location to provide you with a better service experience.

6.13. Liability. We are fully responsible, in all applicable cases, for ensuring that the collection and processing of personal data comply with Regulation requirements, as well as for any consequences resulting from the breach of Regulation provisions.

7. YOUR RIGHTS

7.1. Right to Information: the right to receive clear and understandable information about what personal data is being collected, how it is used, with whom it may be disclosed, and how long it will be retained. All of this information consists at scope of our documents: Privacy Policy, DPA, Tracking Technology Policy and Subprocessor list. You may also always contact us with any request regarding your personal data at the Our email

7.2. Right to Access: the right to request a copy of Your personal data held by Us and obtain information about its processing. To exercise this right, please contact us via email at Our email and we will provide you with a copy of your personal data;

7.3. Right to rectification: the right to request the correction of inaccurate or incomplete personal data concerning them. You can do this yourself in your Account or provide us with instructions by sending them to Our email;

7.4. Right to erasure (Right to be Forgotten): the right to request the deletion of Your personal data when it is no longer necessary for the purposes for which it was collected or when You withdraws Your consent. You can do this yourself by providing us with instructions by sending them to Our email (Except where this right is restricted in accordance with the provisions of Articles 17 and 18 of the GDPR);

7.5. Right to Restriction of Processing: the right to restrict the processing of Your personal data under certain circumstances, such as disputing the accuracy of the data or the lawfulness of its processing. To exercise this right, please contact us via email at Our email and we will restrict Your personal data in accordance with your instructions;

7.6. Right to Data Portability: the right to receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another organization, where technically feasible. To exercise this right, please contact us via email at Our email and we will provide you with a copy of your personal data.

Right to Withdraw Consent: the right to withdraw Your consent at any time. You can withdraw your consent at any time by sending us a corresponding message to Our email;

7.7. Right to Object: the right to object to the processing of your personal data based on our legitimate grounds. For example, this may occur when you believe that the processing of your data infringes upon their rights and freedoms, or when you/they do not wish their data to be used for direct marketing purposes. To exercise this right, please contact us via email at Our email and we will provide you with a copy of your personal data.

7.8. Right to Lodge a Complaint: the right to lodge a complaint with the relevant data protection authority if You believe that your rights regarding the protection of personal data are violated. In such cases, you have the right to lodge a complaint with the relevant supervisory authorities without any limitations. Here is a list of all the supervisory authorities responsible for personal data protection in the EU: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

8. PRIVACY AND SECURITY

8.1. Considering the current advancements in technology, implementation costs, nature, scope, context, and purposes of the Processing, as well as the varying risks associated with potential harm and the severity of such harm (its impact) on the rights and freedoms of data subjects, we employ suitable technical and organizational measures to ensure an appropriate level of security commensurate with these risks. These measures may include those outlined in Article 32(1) of the GDPR.

8.2. During the provision of the Service, we assess the appropriate level of security by taking into account the risks associated with the Processing, particularly those arising from potential breaches of personal data security.

8.3. Privacy of communication. We guarantee the security of the content of your communication with us

8.4. Actions in the event of a Personal data breach. We pledge to promptly notify you upon becoming aware of a Personal Data security breach (a security incident) that adversely affects Your information and/or Information about you. In such cases, we will provide you with all available information concerning the security incident, enabling you to fulfill any obligations to notify or inform Data Subjects, supervisory and/or regulatory authorities about the personal data breach in accordance with the Regulation. We will send this notification to the email address associated with your Account.

9. OTHER

9.1. Changes. In line with our ongoing efforts to enhance personal data processing procedures and expand the features of the Service, you acknowledge and agree that we retain the right to modify this Policy at our sole discretion, at any time. We will inform you about any changes by sending a notification to the email address associated with your Account. Additionally, if you have opted out of receiving such email notifications, we will provide a link on this page to access the previous version of the Policy at the time of each update

9.2. Communication. On our Website you have the opportunity to contact us to ask questions, for example via the contact form or via online-chat, we ask you for your contact information (e.g. name, email address, etc.), a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue. We use this data in connection with answering the queries we receive. If you receive emails from us, we may use certain analytics tools, to capture data such as when you open our email or click on any links or banners our email contains. This data helps us to gauge the effectiveness of our communications and marketing campaigns. On our Website it is also possible to request a phone call. In that case, we ask you for a contact phone number. Through the phone call, you may also share with us your personal information that we may use during the phone call and later for the purpose of improving the level of our services and other marketing purposes (also for these purposes the phone call may be recorded).

We may send you notification emails about updates to our product, legal documents, offer customer support or marketing emails. Except for cases where we are required to do so by law (e.g. notifying you of a data breach) or for providing to you a normal usage of Ringostat service (e.g. service messages for password recovery etc.), you have the opportunity to unsubscribe from receiving these messages free of charge.

9.3. Account registration. When the Visitor create an account an account data processes for the purposes of operating our website, identification you as a user, providing our services (e.g. sending reports), ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.

9.4. Contact our Data Protection Officer:

Yurii Bondar

Email: [email protected]

Address: 41 Devonshire Street, Ground Floor, London, United Kingdom, W1G 7AJ

Privacy Policy

what is it about?

This document outlines our procedures for collecting and processing user personal data, describing the relevant processes and informing users of their data rights. We want you to have a clear understanding of how your data will be processed.

The regulation of all our processes for the collection and processing of user personal data is governed by the entirety of the provisions of four documents, namely, this Policy and:

  • Data Processing Agreement — the primary document regulating the processes of processing personal information of users who have registered an account and use the RINGOSTAT service. The provisions of this document complement, specify, amend, or replace certain terms of this policy. The DATA PROCESSING AGREEMENT provisions take precedence in legal force over this policy in case of any discrepancies DATA PROCESSING AGREEMENT  between and policy.
  • Subprocessor List — this document contains information about the purposes of transferring user personal data to third-party services and companies that we engage for the operation of RINGOSTAT service.
  • Cookie Policy — this document outlines the usage of tracking technologies and includes information about the technologies themselves, the purposes of collecting and processing personal data, and a description of user privacy controls and settings.

We kindly request that you familiarize yourself with all the specified documents, as their provisions directly affect your personal data.

If any provision of the specified documents:

  • is unclear or raises questions for you, we kindly ask you to contact us for clarification via our email. We will explain the meaning of such provision(s). 
  • is not suitable for you or you disagree with certain provision(s), we kindly ask you to refrain from using our website and the RINGOSTAT service.

We also require individuals who have not reached the age of 18 (i.e., adulthood) to cease using our website. Additionally, if the local legislation of the country where you are a resident imposes a higher age requirement for using RINGOSTAT  services, that higher age requirement shall apply. 

1. APPLICABLE TERMS

In this document, we will be using specific terms. It is important for us that we interpret them consistently with you. That is why we have created this section.

1.1. We refers to Netpeak LTD, a limited liability company with its principal place of business at 41 Devonshire Street, Ground Floor, London, United Kingdom, W1G 7AJ.

1.2. RINGOSTAT service denotes the object of intellectual property rights, namely the computer program (software product) namely "RINGOSTAT," accessible to users via the internet on the website.

1.3. Visitor means an individual who accesses the website but does not have a registered account.

1.4. Account refers to the tool that provides access to the RINGOSTAT service. It features a virtual section on our website for configuring, managing, and controlling the RINGOSTAT service, selecting functionality, adjusting project settings, viewing usage statistics, and more.

1.5. Website means our internet resource located at the address: https://ringostat.com.  

1.6. Our email refers to a specially created email address by us: [email protected], used for communication with data subjects regarding the collection and processing of their personal data, including processing instructions regarding personal data.

1.7. GDPR refers to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), available at the following link: https://eur-lex.europa.eu/eli/reg/2016/679/oj

1.8. The terms: "Personal data", "Sensitive data", "Controller", "Processor", "Processing", "Data subject consent", "Data subject" and "Personal data breach" carry the meanings as defined by the GDPR. 

2. OUR ROLES

2.1. When using our website without registration we act as the data controller (as we independently determine the purposes and means of processing the personal data received), and the visitor is the data subject (as you share your personal data with us).

After creating an Account, our relationship and roles regarding personal data is governed by the Data Processing Agreement

3. PURPOSES OF PROCESSING

3.1. The purposes of processing your personal data. The processing of such information serves the following purposes: 

  • account registration in the RINGOSTAT service;
  • marketing and communication with you;
  • compliance with legal requirements;
  • ensuring and/or enhancing the level of security of the RINGOSTAT service;
  • investigating fraud, spam, improper or illegal use of the RINGOSTAT service;
  • improvement of the RINGOSTAT service as a product;
  • proposal for you to enter into a contract and the related communication.;
  • other purposes expressly provided for by current legislation or a requirement of a governmental authority.

We acknowledge that any purposes not explicitly stated in this paragraph are limited to our own use.

4. BASIS OF PROCESSING

Until you have an Account with the RINGOSTAT service, there are three ways through which we may obtain your personal data:

  • through the use of cookies; 
  • from communicating with you;
  • through the erasure google form (clause 6.4. (b) of this Policy).

4.1. The legal basis for processing your personal data.

If you are the visitor.

  • personal data collected through the cookies. When using cookies, we rely on the visitor's consent for the processing of their personal data for one or more purposes outlined in section 3.1. of this Policy. The description of the technologies, their types, the categories and purposes of collecting personal data using these technologies, the procedure for providing, modifying settings, or withdrawing consent for the processing of personal data is regulated by the Cookie Policy
  • any other personal data. We rely on legitimate interest as the legal basis for the collection and processing of personal data that we obtain for and as a result of communication with you (including the use of email, technical support service, 1"Contact Us" module). Our legitimate interest includes: 
    — offering and coordinating the use of the website and/or RINGOSTAT service; 
    — providing technical support for the use of the website and/or RINGOSTAT service;
    — clarifications regarding payments or specific features of the RINGOSTAT service;
    — investigation or assisting and advising on issues related to illegal activities prevention or IT system security breaches.
    ‍
    1 The "Contact Us" module is located in the bottom right corner of our website screen. The mentioned module will be unavailable for use if the "Preferences" cookies are disabled.

If you`re not the visitor:

other legal grounds and methods for collecting and processing personal data are determined by the , Data Processing Agreement ,
which comes into effect upon the visitor's account registration.

5. CATEGORIES OF PERSONAL DATA

5.1. Visitor`s data. We collect and process the following categories of visitor`s personal data:

  • Identity Data: includes visitor`s location, preferences, IP addresses, device information, operating system, screen resolution, language, country you are located in, language and marketing preferences, the date and duration of your visit, visited pages, your GA ClientID, browsing history and activity on a website. 
  • Contact Data: This category comprises email addresses, phone numbers, voice, messenger identifiers and/or any other contact information that you may provide us through the communication with us.
6. PROCESSINg

6.1. Our processing of visitor`s Personal Data. we process such data based on the following principles and grounds:

  • Lawfulness, fairness, and transparency: we process personal data based on your consent or on our legitimate interest, and this process is open and transparent. You can withdraw your consent and/or you may restrict our legitimate interest; 
  • Purpose limitation: we receive and process data solely for the purposes stated in Clause 3.1 of this Policy.
  • Data minimization: we receive and process only the amount of data necessary to achieve our defined purposes;
  • Accuracy: we enable you to maintain the accuracy of your personal data and will update them when necessary, according to your instructions;
  • Storage limitation: we retain the received personal data only for the necessary period to achieve the defined purposes (clause 6.7. of this Policy);
  • Integrity and confidentiality: we ensure an appropriate level of protection for the personal data we receive, safeguarding them against unauthorized access, loss, or damage.
  • Accountability:  we are responsible for complying with this Policy, ensuring proper processing of personal data and ensuring our activities align with the requirements of the GDPR.

6.2. Your instructions. We process your information based on your instructions. Your instructions encompass the actions and settings performed within the website, as well as the instructions that we obtain from you through our communication. 

6.3. However, if we are unable to fulfill any of your instructions regarding the processing of personal data at any point during our cooperation, we will notify you of the impossibility and may refuse further use of the personal data received from you. In such cases, we will delete all personal data received from you, and you acknowledge that our actions cannot be considered a violation of your rights and/or interests or cause harm.

For example. You have contacted us through the "Contact Us" module with a question regarding the use of one of the features of our product. For communication purposes, you provided the email address [email protected] and requested a response to be sent to that address. After we sent a reply to the email address you provided, we received a message (for example, from the same email address or through the "contact us" module) requesting an explanation regarding: 

  • how we obtained this email address, 
  • why we are sending massages to it,
  • why we are processing it (email as a personal data),
  • to delete the email from all our databases (right to be forgotten).

Since we cannot independently verify whether the email address belongs to you or another person (the party who sent us the aforementioned requests), we are obliged to comply with the demands of the party contacting us and delete the corresponding data from our servers. 

Our actions in this matter are justified by the balance of interests between the individual who may actually own the specified email address, your interest in communicating with us or receiving subsequent consultations regarding the capabilities of our product, and the interests of the individual who does not actually own the email address (if the party who sent us the specified requests has no association with the email address). In our view, the right to erasure (as well as other rights provided by the Regulation) of the individual who may genuinely own the email address prevails over the interests of other individuals in such situations.

In all similar cases (i.e., when we receive instructions from a third party regarding their personal data and cannot verify the identity of the data subject), we will consider the individual making such request to be the data subject, and therefore, we will prioritize the execution of such instructions.

6.4. Data management, withdrawal of consent and right to be forgotten. When using the website, you can instruct us at any time: 

  • To withdraw your consent for the collection and processing of specific categories of personal data carried out through the cookies, please navigate to the "Cookie Settings" module located in the bottom left corner of the screen. Upon deactivating the relevant category in this module, we will cease the collection and processing of the corresponding category of personal data. Data collected prior to your settings change will be deleted within the timelines determined by the respective the cookies (further details about the timelines can be found in the Cookie Policy
  • to exercise the right to be forgotten. For this purpose, we have prepared a 2"Google form. By filling out and submitting this form, we will process your instruction. Note that the data, including personal data, received through the filled-out Google form as well as data that we obtained as a result of communicating with you regarding the exercise of the right to be forgotten, will be retained for 5 years from the date of receiving the form. This is necessary for our protection in case an individual, following the instructions provided through Google Forms, deletes a volume of personal data that does not belong to them and for which they have no rights.

You can also always email us, and we will assist you in composing your instructions.

2 For convenience, we also provide a duplicate link to the Google Form at the end of this document.

6.5. Our warranties.  We guarantee and commit to:

  • complying with GDPR requirements and notifying you in case of any non-compliance.
  • never sell your personal data or disclose it to any other persons or in any manner not outlined in this Policy.

6.6. Automated Decision-Making. We do not use automated decision-making technologies and/or algorithms in RINGOSTAT service and Website.

6.7. Processing Period. The commencement of the processing period of your personal data shall be the day on which you accepted the terms of this Policy. The termination of the processing period for personal data, depending on the circumstances, shall be:

  • the last calendar day of the fifth year from the day you last used RINGOSTAT service, or
  • the day you withdraw your consent for the processing of personal data, or
  • the retention and processing periods (cookie lifetime period) for data collected through the cookies are defined in the Cookie Policy

6.8. Liability. We are fully responsible, in all applicable cases, for ensuring that the collection and processing of personal data comply with GDPR requirements, as well as for any consequences resulting from the breach of Regulation provisions.

7. YOUR RIGHTS

7.1. Information. Receive clear and understandable information about what personal data is being collected, how it is used, with whom it may be disclosed, and how long it will be retained. All of this information consists at scope of our documents: this Policy, Data Processing Agreement, Cookie Policy, Subprocessor List. You may also always contact us with any request regarding your personal data at the Our email;

7.2. Access. Request a copy of Your personal data held by Us and obtain information about its processing. To exercise this right, please contact us via email at Our email and we will provide you with a copy of your personal data;

7.3. Rectification. Request the correction of inaccurate or incomplete personal data concerning them. You can do this yourself in your Account or provide us with instructions by sending them to Our email;

7.4. Erasure (right to be forgotten). Delete your personal data when it is no longer necessary for the purposes for which it was collected or when you withdraw your consent. You can do this yourself by providing us with instructions by sending them to Our email (Except where this right is restricted in accordance with the provisions of Articles 17 and 18 of the GDPR);

7.5. Withdraw consent. Withdraw your consent at any time. You can withdraw your consent at any time by sending us a corresponding message to Our email;

7.6. Restriction of processing. Restrict the processing of your personal data under certain circumstances, such as disputing the accuracy of the data or the lawfulness of its processing. To exercise this right, please contact us via email at Our email and we will restrict Your personal data in accordance with your instructions;

7.7. Data portability Receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another organization, where technically feasible. To exercise this right, please contact us via email at Our email and we will provide you with a copy of your personal data.

7.8. Object. Object to the processing of your personal data based on our legitimate grounds. For example, this may occur when you believe that the processing of your data infringes upon their rights and freedoms, or when you/they do not wish their data to be used for direct marketing purposes. To exercise this right, please contact us via email at Our email and we will provide you with a copy of your personal data.

7.8. Lodge a complaint. Lodge a complaint with the relevant data protection authority if you believe that your rights regarding the protection of personal data are violated. Here is a list of all the supervisory authorities responsible for personal data protection in the EU: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

8. PRIVACY AND SECURITY

8.1. Considering the current advancements in technology, implementation costs, nature, scope, context, and purposes of the Processing, as well as the varying risks associated with potential harm and the severity of such harm (its impact) on the rights and freedoms of data subjects, we employ suitable technical and organizational measures to ensure an appropriate level of security commensurate with these risks. These measures may include those outlined in Article 32(1) of the GDPR. 

8.2. During the provision of the website and RINGOSTAT service, we assess the appropriate level of security by taking into account the risks associated with the Processing, particularly those arising from potential breaches of personal data security. 

8.3. Privacy of communication. We guarantee the security of the content of your communication with us. 

8.4. Actions in the event of a Personal data breach. We will promptly notify you of any security incident (personal data breach) affecting your information. In such cases, we'll offer detailed information to help you meet notification obligations to data subjects and regulatory authorities. We will strive to localize, minimize, and assess the impact of the breach as per GDPR requirements. Our actions will focus on reducing harm to data subjects, and notifications will be sent using available contact details.

9. OTHER

9.1. Changes. In line with our ongoing efforts to enhance personal data processing procedures and expand the features of the RINGOSTAT service, you acknowledge and agree that we retain the right to modify this Policy at our sole discretion, at any time. We will inform you about any changes by sending a notification to the email address associated with your Account. Additionally, if you have opted out of receiving such email notifications, we will provide a link on this page to access the previous version of the Policy at the time of each update.

9.2. Communication. When you contact us through our website, using methods such as the contact form or online chat, we request your contact information (e.g., name, email address) along with a summary of the issue and any supporting documentation, screenshots, or relevant information. This data is utilized to address your inquiries. For emails we send, analytics tools may be employed to track actions such as email opens, link clicks, or banner interactions, aiding us in assessing the effectiveness of our communication and marketing efforts. If you request a phone call, we ask for your contact phone number. During the call, you may share personal information, which we may use to enhance the RINGOSTAT services and for marketing purposes. Phone calls for these purposes may be recorded. 

You may receive notification emails regarding product updates, legal documents, customer support, or marketing emails. You can opt out of these messages at no cost (an unsubscribe button is provided at the end of each email). Exceptions include cases required by law (e.g., notifying you of a data breach) or for facilitating the normal use of the RINGOSTAT service (e.g., service messages for password recovery).

9.3. Account registration. When the visitor create an account data processes for the purposes of operating our website, identification you as a user, providing the RINGOSTAT services (e.g. sending reports), ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.

9.4. Our Data Protection Officer:

Yurii Bondar

Email: [email protected]

Address: 41 Devonshire Street, Ground Floor, London, United Kingdom, W1G 7AJ

9.5. Our EU representative:

NETPEAK EOOD (LTD) 

Email: [email protected]

Legal address: 47 Cherni vrah blvd., 1407 Sofia, Bulgaria 

10. RIGHT TO ERASURE GOOGLE FORM.
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