Privacy Policy

Before using FAIRO application (the Application) or signing up on its website https://www.fairo.com.ua/ (the Website), you are required to familiarize yourself with and accept this Privacy Policy (the Policy) regulating the collection, processing, use and transfer of your personal data.

The Policy applies if you are an individual user of the Application. The expression "individual user" also includes individual entrepreneurs. We may need to update this Policy from time to time. Where a change is significant, we’ll make sure we let you know by sending you an email and/or posting an updated version of the Policy in the Application.

Your Consent

By switching the tick box to the right position in a confirmation dialog box appearing in the Application during the sign-up process or signing up on the Website you accept this Policy and therefore grant a consent to FAIRO LLC, legal entity incorporated under the laws of Ukraine, identification number 43659053, registered address: Ukraine, 04073, Kyiv, 9 Stepana Bandery Avenue, building 5 A, 2d floor (the Provider), as a data controller, to process your personal data in a scope and for the purposes described herein, in connection with your entering into agreement with the Provider (the Agreement) in respect your use of the Application.

In the Application you may have access to services of the third parties other than the Provider. Your transfer of personal data to such third party providers is not subject to this Policy. In advance to provision of those services you may be required to accept the privacy policy of the respective third parties.

Scope of Personal Data

The scope of your personal data that the Provider may process depends on the Application features you want to use. Minimum scope of your personal data required for entering into Agreement with the Provider, setting up and keeping your Application account include your full name, e-mail address, tax identification number, registered address, login credentials, language, currency and subscription details. To enable you use of various features of the Application on top of the above we also need to get your bank account details (such as bank details and account number) and taxpayer information. As long as you will use the payment account synchronization features of the Application the Provider will process also credentials to access the payment account, transaction details (such as amount, description, date and currency) and the payment account details (such as bank details, account number, account name, balance, currency, and type of account) which we receive through our subcontractor Salt Edge Inc. We may receive information about your business, finances, expenses, invoices, financial statements, details of your financial transactions, payroll details, payment details, tax return details, details about your customers or vendors or employees, income and wage information, and/or investment information. Certain features of the Application may also have access to your device gallery, camera and contacts if you grant permission in your device settings. On the Website we only collect your e-mail address. Where any your personal data is publicly available in the state registers due to your registration as an individual entrepreneur, we may receive it from our subcontractor You-Control LLC.

Purpose of Your Personal Data Processing

Your personal data are processed to operate our business related to the Application, namely, to:

  • set up and keep your Application account to enable your use of the Application and its features;
  • improve the Application's features and services;
  • inform the Application users that you are the user of the Application;
  • run and manage our business related to the Application, including resolving billing and financial disputes;
  • evaluate your eligibility for our offers, products and services;
  • connect you with other users;
  • communicate with you;
  • advertise and market our services and experiences;
  • personalize your experience, including through the development of insights about you and your needs;
  • provide you with support and resolve disputes;
  • conduct researches, including based on anonymized data;
  • comply with our legal and regulatory requirements;
  • execute, perform, enforce, remedy or otherwise apply the Agreement.

Your personal data collected on the Website are processed to:

  • facilitate your access to the Application (by sending you the link to the Application etc.);
  • advertise and market our services and experiences.

Sending Marketing Communications

You acknowledge that the Provider, as a data controller, may use your email address and other details it has obtained in the course of registration to send you direct marketing communications regarding the Application. Your e-mail may be used by the Provider until you opt out. You can opt out at any time by clicking on the "unsubscribe" link in the respective e-mail or by another action described therein.

Marketing

You can give the Provider, as a data controller, consent to process your personal data for marketing purposes, particularly in order to create audiences and otherwise personalize your ad experience, including marketing communications. We may also freely use, distribute and share with the general public your name, photo uploaded to the Application and any your suggestions, comments, ideas or other feedback you may provide in connection with the Application and its services to advertise and promote the Application. The personal data will be processed by the Provider for marketing purposes until you withdraw your consent. You can withdraw your consent at any time within the Application.

Transfers to Third Party Recipients

The Provider may appoint third parties to perform some of the personal data processing operations, however, only for the purposes specified in this Policy, on a basis of written agreement and in accordance with applicable law.

Otherwise the Provider does not transfer or disclose your personal data to any third parties, unless you have consented otherwise under this Policy or initiated the disclosure or except as required by the applicable laws.

Other users of the Application may be informed that you are using the Application. Sharing your personal data with other users of the Application is completely under your control.

Data processors being used by the Provider include (and where the data processor is located outside European Economic Area you explicitly consent to transfer of your personal data to such data processor)

  • Creative Dock AT GmbH, Landstraßer Hauptstraße 14-16 1090 Vienna
  • CreativeDock s.r.o., Zubatého 295/5, Smíchov, 150 00 Praha 5, Czech Republic
  • Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland
  • Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
  • Facebook Inc., 1601 Willow Road, Menlo Park, CA 90425, USA
  • You-Control LLC, 1A Shumskogo Str., office 117, Kyiv, 02098, Ukraine
  • Liga Zakon LLC, 23 Parkovo-Syretska Str., Kyiv, 04112, Ukraine
  • Salt Edge Inc., 35 Jack Aaron Drive, Ottawa, Ontario, K2G 6L2, Canada
  • Zendesk, Inc., 1019 Market Street, San Francisco, CA 94103, USA

Your Rights

Pursuant to the Law of Ukraine "On personal data protection" you have the right to:

  • know about the sources of collection, location of your personal data, purpose of their processing, location and/or place of residence (temporary residence) of the controller or processor of personal data, or to issue a respective request on obtaining such information to the authorized persons, except for cases established by the law;
  • receive information on conditions of access to personal data, in particular information about third parties your personal data are transferred to;
  • access to your personal data;
  • receive a response with regard to whether your personal data are processed as well as to receive information on the content of your personal data within the period that is no longer than 30 days since the moment the relevant request was received, unless otherwise prescribed by law;
  • submit a motivated request to controller of personal data with objection against processing of your personal data;
  • submit a motivated request to change or delete your personal data by any controller and processor of personal data, if such data are processed illegally or are inaccurate;
  • protect your personal data from illegal processing and accidental loss, destruction, damage due to a deliberate concealing, failure to provide them or provision of such data with delay, as well as to protection from provision of data which are inaccurate or disgraceful for the honor, dignity and business reputation of an individual;
  • submit complaints on your personal data processing to the Ukrainian Parliament Commissioner for Human Rights or courts;
  • use legal remedies in case of violation of legislation on protection of personal data;
  • make reservations to restrict the right to process your personal data while providing your consent;
  • withdraw consent to the processing of your personal data;
  • know the automatic mechanism of processing of personal data; and
  • be protected from automated decision that has legal consequences for you.

Payment Information and Online Banking Credentials

When you make purchases through the Application, your credit card information and other data are not collected and stored by the Provider, but only by third party payment processors.

In case you use the payment account synchronization feature of the Application, your online banking credentials are by default used only upon your manual entry, securely encrypted and stored by Salt Edge Inc. as a data processor.

Location

Some of the Application's features may access and collect your current location data, including GPS coordinates or other similar information regarding the location of your device. Some features of the Application may not function properly if use of location data is blocked or disabled.

Technical Data

You acknowledge that Provider may collect and use technical data, including but not limited to information about your mobile device and system, Internet connection or your use of the Application. The purpose of the collection of technical data is to ensure quality, increase your comfort and further analyze and develop the Application and related services.

Technical data is anonymous and stored separately from the personal data, therefore it cannot be linked back to you in any way in order to identify you.

Cookies

Cookies are small pieces of data that are stored on your device to help mobile applications like the Application to remember certain information. Cookies may contain personal data. The Application is using cookies in order to keep your settings, for security reasons, to analyze your use of the Application and for targeting advertisement. You can always block use of cookies or delete existing cookies by changing the settings of your browser or device, however it can affect the functionality of the Application.

Data Security

Your personal data is stored and processed automatically in electronic form on secure servers using the cloud technology provided by Amazon Web Service, Inc.. The respective database servers are located in Germany. Provider and its subcontractors have to always comply with its high data protection standards. You acknowledge, that even Provider, Salt Edge Inc. and other data processors use all standard security measures, the security of your personal data and other information can't be fully guaranteed.

Removal of Your Personal Data

Your personal data will be processed by the Provider until you withdraw your consent to processing of your personal data by the Provider or terminate the Agreement, whichever occurs first, and in either case your personal data will be removed by the Provider from its databases within three (3) months following such withdrawal or termination. As long as your personal data are depersonalized and cannot be attributed to you such data can be stored and processed by the Provider for unlimited period of time.

Contact Information

If you have any queries relating to the protection and security of your data, please contact Provider at support@fairo.com.ua or at the following postal address: 9 Stepana Bandery Avenue, building 5 A, 2d floor, Kyiv, 04073,Ukraine.