PRIVACY POLICY

This Privacy Policy has been developed taking into account Our awareness of the importance and significance of Your Personal Data. The main purpose of this Policy is to help You understand how We Process and protect Your Personal Data when You use the Site and/or App.

This Privacy Policy is developed and operates taking into account the General Data Protection Regulation (GDPR), the General Data Protection Regulation of Great Britain (UK GDPR), California Consumer Privacy Act of 2018, California Online Privacy Protection Act of 2003, Law of Ukraine “On Personal Data Protection” №2297-VI dd. 01.06.2010, the Personal Information Protection and Electronic Documents Act, Personal Information Protection Act of British Columbia, Personal Information Protection Act of Alberta, and Act respecting the protection of personal information in the private sector of Quebec, as well as other regulations and practices on the protection of Personal Data.

By using this Site, You confirm that You have reached the age from which the legislation of the country of Your stay allows You to give Consent to the Processing of Your Personal Data. In any case, in order to use the Site, You must be at least 16 years old (at least 13 years old in certain regions) or one of Your legal representatives or guardians must have read and agree to the terms of this Privacy Policy on behalf of You. If You do not agree or cannot confirm the above, You must immediately stop using the Site. In this case, You must (a) contact Us and request the deletion of Your Data; (b) leave the Site and not use it.

Terms used in this Privacy Policy:

“Privacy Policy” – this document, which is available at the following link: https://www.highfigure.net/docs/privacy-policy/ (hereinafter — “Policy”, “Privacy Policy”).

“Company” — PE Volkov Oleksii Oleksiovych, identification number: 2868504172, who is registered at: 69097, Ukraine, Zaporizhzhia region, Zaporizhzhia city, Inzhenera Preobrazhenskoho Ave 7 (hereinafter — “Company”, “We”, “Us”, “Our”).

“Personal Data” — any information relating to a natural person who is identified or can be identified using this information (hereinafter — “Personal Data”, “Data”).

“Processing of Personal Data” – any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (hereinafter — “Processing”, “Processing of Personal Data”, “Process”).

“Subject of Personal Data” – a person who visits and/or uses the Site within the scope of its available functionality and in accordance with the documentation contained on the Site (hereinafter — “User”, “You”, “Your”).

“Controller” – the Company, which determines the purposes and means of Personal Data Processing, establishes the composition of this Personal Data and the procedures for its Processing.

“Processor” – the Company or other persons that are authorized by the Controller or by law to Process Personal Data on behalf of the Controller.

“Site” — the website of the Company, https://www.highfigure.net, all its content and links that lead to this website.

“App” — the application USBoNET (USB Over Network) software product, the download page for which is available at the following link: https://www.highfigure.net/product/usbonet/, and encompasses all elements within the files provided by the Company.

“Services” — services to provide You with permanent access to the Site / App.

“Consent” — any freely given, specific, informed, and unequivocal indication of the Subject of Personal Data wishes by which he or she, through clear affirmative actions, signifies agreement to the Processing of his or her Personal Data.

“Cookies” — files that are downloaded to the User’s computer or any other device when the User visits the Site. These types of files allow Us to store and research information about the preferences of the User on the Site.

“General Data Protection Regulation” — European Parliament and Council Regulation № 2016/679 as of 27.04.2016 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 (hereinafter — “GDPR”).

“UK GDPR” — Data Protection Act 2018, a regulation incorporated into the legislation of the United Kingdom of Great Britain and Northern Ireland as amended by the Data Protection, Privacy, and Electronic Communications Regulations.

“CCPA” – California, USA Consumer Privacy Act of 2018.

“CalOPPA” – The Internet Privacy Protection Act of 2003 of the State of California, USA.
Questions or concerns? Reading this Privacy Policy will help You understand Your privacy rights and choices. If You do not agree with Our policies and practices, please do not use Our Services.

SUMMARY OF KEY POINTS

This summary provides key points from Our Privacy Policy, but You can find out more details about any of these topics by clicking the link following each key point or by using Our table of contents below to find the section You are looking for.

What Personal Data do We Process? When You visit, use, or navigate Our Services, We may Process Your Personal Data depending on how You interact with Us and the Services, the choices You make, and the products and features You use. Learn more about Personal Data You disclose to Us.

Do We receive any Data from third parties? We may receive information from some third party. Learn more about information collected from other sources.

How do We Process Your Data? We Process Your Data to provide, improve, and administer Our Services, communicate with You, for security and fraud prevention, and to comply with law. We may also Process Your Data for other purposes with Your Consent. Furthermore, We Process Your Data only when We have a valid legal reason to do so. Learn more about how We Process Your Data.

In what situations and with which parties do We share Personal Data? We may share Data in specific situations and with specific third parties. Learn more about when and with whom We share Your Personal Data.

How do We keep Your Personal Data safe? We have organizational and technical processes and procedures in place to protect Your Personal Data. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat Our security and improperly collect, access, steal, or modify Your Data. Learn more about how We keep Your Personal Data safe.

What are Your rights? Depending on where You are located geographically, the applicable privacy law may mean You have certain rights regarding Your Personal Data. Learn more about Your privacy rights.

How do You exercise Your rights? The easiest way to exercise Your rights is by submitting a data subject access request, or by contacting Us. We will consider and act upon any request in accordance with applicable data protection laws. Want to learn more about what We do with any Personal Data We collect? Review the Privacy Policy in full.

1. WHAT PERSONAL DATA DO WE COLLECT?

2. HOW DO WE PROCESS YOUR PERSONAL DATA?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL DATA?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. HOW LONG DO WE KEEP YOUR DATA?

7. HOW DO WE KEEP YOUR DATA SAFE?

8. DO WE COLLECT DATA FROM MINORS?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

13. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

14. DISPUTE RESOLUTION

15. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT PERSONAL DATA DO WE COLLECT?

Personal Data You provide to Us personally:

In Short: We collect Personal Data that You provide to Us.

We collect Personal Data that You voluntarily provide to Us when You express an interest in obtaining information about Us or Our products and Services, when You participate in activities on the Services, or otherwise when You contact Us.

Personal Data Provided by You. The Personal Data We collect may include the following:

full name;
email address;
username.

Personal Data automatically collected

In Short: Some Personal Data – such as Your Internet Protocol (IP) address and/or browser and device characteristics – is collected automatically when You visit Our Services.

We automatically collect certain Data when You visit, use, or navigate the Services. This information does not reveal Your specific identity (like Your name or contact information) but may include device and usage information, such as Your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when You use Our Services, and other technical information. This information is primarily needed to maintain the security and operation of Our Services, and for Our internal analytics and reporting purposes.

Like many businesses, We also collect information through Cookies and similar technologies.

The Data We collect automatically includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information Our servers automatically collect when You access or use Our Services and, which We record in log files. Depending on how You interact with Us, this log data may include Your IP address, device information, browser type, and settings and information about Your activity in the Services (such as the date / time stamps associated with Your usage, pages and files viewed, searches, and other actions You take such as which features You use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).

Personal Data collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

In order to enhance Our ability to provide relevant marketing, offers, and Services to You and update Our records, We may obtain Data about You from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or User behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion.

2. HOW DO WE PROCESS YOUR PERSONAL DATA?

In Short: We Process Your Data to provide, improve, and administer Our Services, communicate with You, for security and fraud prevention, and to comply with law. We may also Process Your Data for other purposes with Your Consent.

We Process Your Personal Data for a variety of reasons, depending on how You interact with Our Services, including:

To deliver and facilitate delivery of Services to the User. We may Process Your Data to provide You with the requested Service.

Management and improvement of the Site / Services. All the time, We try to improve the functions that support the operation of the Site / Services. This allows Users to use the Site / Services smoothly, quickly and efficiently.

To respond to inquiries / offer support. We may Process Your information to respond to Your inquiries and solve any potential issues You might have with the requested Service.

Compliance and security. Personal Data Processing is essential for ensuring compliance with legal obligations, such as tax regulations and consumer protection laws, as well as for implementing security measures to protect against unauthorized access, fraud, and other security threats.

To send administrative information to You. We may Process Your Data to send You details about Our products and Services, changes to Our terms and policies, and other similar information.

To enable User-to-User communications. We may Process Your information if You choose to use any of Our offerings that allow for communication with another User.

To request feedback. We may Process Your Data when necessary to request feedback and to contact You about Your use of Our Services.

To send You marketing and promotional communications. We may Process the Personal Data You send to Us for Our marketing purposes, if this is in accordance with Your marketing preferences. You can opt out of Our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?” below.

To save or protect an individual’s vital interest. We may Process Your Data when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL DATA?

In Short: We only Process Your Personal Data when We believe it is necessary, and We have a valid legal reason (i.e., legal basis) to do so under applicable law, like with Your Consent, to comply with laws, to provide You with Services to enter into or fulfill Our contractual obligations, to protect Your rights, or to fulfill Our legitimate business interests.

The GDPR and UK GDPR require Us to explain the valid legal bases We rely on in order to Process Your Personal Data. As such, We may rely on the following legal bases to Process Your Personal Data:

Consent. We may Process Your Data if You have given Us permission (i.e., Consent) to use Your Personal Data for a specific purpose. You can withdraw Your Consent at any time. Learn more about withdrawing Your Consent.

Performance of a contract. We may Process Your Data when We believe it is necessary to fulfill Our contractual obligations to You, including providing Our Services or at Your request prior to entering into a contract with You.

Legitimate interests. We may Process Your Data when We believe it is reasonably necessary to achieve Our legitimate business interests and those interests do not outweigh Your interests and fundamental rights and freedoms. For example, We may Process Your Personal Data for some of the purposes described in order to:

Send Users information about special offers and discounts on Our products and Services;
Understand how Our Users use Our products and Services so We can improve User experience.

Legal obligations. We may Process Your Data where We believe it is necessary for compliance with Our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend Our legal rights, or disclose Your Data as evidence in litigation in which We are involved.

Vital interests. We may Process Your Data where We believe it is necessary to protect Your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

In Short: We may share Personal Data in specific situations described in this section and/or with the following third parties.

In some cases, Personal Data may be available to certain categories of Company’s responsible persons (officials), whose activities are related to ensuring the proper functioning of the Site, or to third-party organizations (such as independent providers of technical services, postal organizations, hosting service providers, companies — providers of information technologies, communication services), contractors and partners of the Company, whom We entrust to perform the functions of the Processor if necessary. You can additionally ask Us for a list of the above-mentioned persons.

IT service providers. We may engage other companies (including foreign ones) that provide administrative and IT services, including hosting services, the use of cloud services, and databases, which will Process the User’s Personal Data on Our behalf in order to provide technical support and proper functioning of the Site. Such companies may access the User’s Personal Data only if it is necessary to carry out the above purposes and in accordance with the provisions of the agreements with these companies on the non-disclosure of confidential information, and such companies are not entitled to use it for any other purpose.

Authorities (of the United Kingdom of Great Britain and Northern Ireland, the European Union, or other countries). We reserve the right to disclose and/or report any Personal Data of the User, if this is required by any law of the UK or the European Union or another normative legal act, or a confirmed legal requirement of state authority and/or local authorities, for the purpose of compliance with the requirements of the laws of the UK and the legislation of the European Union, protection of the integrity of the Site, to fulfill the requests of Users, state authorities and/or local authorities, or for the purpose of facilitating any investigation by law enforcement agencies or an investigation aimed at guaranteeing public (national) security. In some cases, We may also provide the User’s Personal Data to the authorities of the European Union (both national and supranational) and to the authorities of other countries, if such provision of Personal Data is required by law, or in the event of an official request from such an authority as part of a criminal investigation.

Financial institutions (banks, payment services / tools). We can involve financial institutions that provide financial, banking services, payment services / tools, for the possibility of payment for Services. Currently, online payments are carried out using the services of PayPro Global Inc. The PayPro Global Inc. may Process Your Data and transfer such Data to Us. We advise You to further familiarize yourself with PayPro Global privacy policy by clicking here: https://payproglobal.com/users-data-protection.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use Cookies and other tracking technologies to collect and store Your Data.

We may use Cookies and similar tracking technologies (like web beacons and pixels) to access or store Personal Data. Specific information about how We use such technologies and how You can refuse certain Cookies is set out in Our Cookie Policy.

6. HOW LONG DO WE KEEP YOUR DATA?

In Short: We keep Your Data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless otherwise required by law.

We will only keep Your Personal Data for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this Privacy Policy will require Us keeping Your Personal Data for longer than 1 (one) year.

When We have no ongoing legitimate business need to process Your Personal Data, We will either delete or anonymize such Data, or, if this is not possible (for example, because Your Personal Data has been stored in backup archives), then We will securely store Your Personal Data and isolate it from any further Processing until deletion is possible.

7. HOW DO WE KEEP YOUR DATA SAFE?

In Short: We aim to protect Your Personal Data through a system of organizational and technical security measures.

The Company stores Your Personal Data on a closed server. We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any Personal Data We Process. However, despite Our safeguards and efforts to secure Your Data, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat Our security and improperly collect, access, steal, or modify Your Data. Although We will do Our best to protect Your Personal Data, transmission of Data to and from Our Services is at Your own risk. You should only access the Services within a secure environment.

We apply a variety of security measures appropriate to the possible risks.

Organizational measures
Staff training	Internal policies

Technical measures
Restrictions on access to Data	Encryption technologies

Processing of Personal Data is carried out using computers and/or automated means in accordance with procedures and methods that correspond to the purposes of collecting Personal Data.

Please be advised the services are hosted in Finland and the United States.

Your Personal Data that We Process may be transferred and stored outside the European Economic Area (EEA):

if there is no adequate decision by the European Commission regarding the country We transfer Data to, We use adopted standard contractual clauses based on legislation assessments for Data protection during transfer and storage;
if there is an adequate decision by the European Commission regarding the country We transfer Data to, We can transfer Personal Data to that third country without any further safeguard being necessary.

We take the protection of Your Personal Data very seriously. We take all commercially reasonable measures to prevent unauthorized access to Your Personal Data and those data obtained in the process of using the Site. Not only that, but We strive to protect Your Personal Data by various means in order to preserve its confidentiality and integrity, prevent unauthorized use or disclosure of Your Personal Data, and protect Your Personal Data from loss, misuse, disclosure, alteration, and/or destruction.

8. DO WE COLLECT DATA FROM MINORS?

In Short: We do not knowingly Process Data from or market to children under the age of 13 (applies to Users who are residents of countries with a reduced minimum age for Personal Data Processing) and children under 16.

We knowingly do not Process the Personal Data of children under the age of 13 (applies to Users who are residents of countries with a reduced minimum age for Personal Data Processing) and children under 16, and We also do not offer them to use the Services.

If We become aware that a person who has not reached the age from which it is permitted to Process their Personal Data has provided Us with their Personal Data without the Consent of a legal representative, guardian, or other person authorized to provide such Consent, We will take all necessary measures to delete such Data. If You believe We might have any information from or about a child under 16 (or 13 if applicable), please contact Us at dpo@highfigure.net.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), You have rights that allow You greater access to and control over Your Data. You may review, change, or terminate Your account at any time.

You, as a Subject of Personal Data, have the right to interact with its Data directly or through a request to Us. This section describes these rights and how You can exercise them:

Right to access: You can request an explanation of the Processing of Your Personal Data, as well as details regarding the processing activities such as the manner in which the Personal Data are processed, the purpose for which the processing is done, the recipients or the categories of Personal Data recipients, etc.;
Right to rectification: You have the right to obtain the correction, without justified delay, by the Company of inaccurate / unjustified Personal Data, as well as the completion of incomplete Personal Data;
Right to erasure (“right to be forgotten”): You can send Us a request to delete Your Personal Data from Our systems and/or databases. We will remove them unless otherwise provided by law;
Right to restrict the Processing: You may partially or completely prohibit Us from Processing Your Personal Data;
Right to Data portability: You can request to receive all the Personal Data You provided to Us in a structured way, commonly used and in an easy-to-read format, as well as the right for this Data to be transmitted by the Company to another controller, to the extent that the conditions provided for by law are met;
Right to object: You may object to the Processing of Your Personal Data;
Right not to be subject to an automated individual decision: the right not to be the subject of a decision taken solely on the basis of automated processing activities, including the creation of profiles, which produce legal effects concerning the Subject of Personal Data or similarly affect him in a significant measure;
Right to withdraw Consent: You can withdraw Your Consent at any time;
Right to file a complaint: If Your request was not satisfied, You could file a complaint to the regulatory body or competent courts, to the extent You deem necessary.

We will consider and act upon any request in accordance with applicable data protection laws.

If You are located in the EEA or UK and You believe We are unlawfully processing Your Data, You also have the right to complain to Your Member State data protection authority or UK data protection authority .

If You are located in Switzerland, You may contact the Federal Data Protection and Information Commissioner .

Opting out of marketing and promotional communications: You can unsubscribe from Our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that We send, replying “STOP” or “UNSUBSCRIBE” to the SMS messages that We send, or by contacting Us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?“ below. You will then be removed from the marketing lists. However, We may still communicate with You – for example, to send You service-related messages that are necessary for the administration and use of Your account, to respond to service requests, or for other non-marketing purposes.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting You can activate to signal Your privacy preference not to have data about Your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, We do not currently respond to DNT browser signals or any other mechanism that automatically communicates Your choice not to be tracked online. If a standard for online tracking is adopted that We must follow in the future, We will inform You about that practice in a revised version of this Privacy Policy.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If You are a resident of the USA, You are granted specific rights regarding access to Your Personal Data.

This section applies only if You are a resident of certain U.S. states that have implemented state-level privacy laws. You, as a Subject of Personal Data, have some special privacy rights. To use them, please contact Us at dpo@highfigure.net.

Please note! Depending on the state and legislative requirements, We have from 30 to 60 days to exercise Your request, with the right to postpone it for 30 days more.

If Your complaint is not satisfied, You can file a complaint with the Federal Trade Commission.

Your rights vary depending on the laws that apply to You, but may include:

Right	Description	Area
Right to access	You can request an explanation of the processing of Your Personal Data.	California;Colorado;Connecticut;Indiana;Iowa;	Montana;Tennessee;Texas;Utah;Virginia.
Right to correct	You can change the Data if it is inaccurate or incomplete.	California;Colorado;Connecticut;Indiana;	Montana;Tennessee;Texas;Virginia.
Right to delete	You can send Us a request to delete Your Personal Data from Our systems.	California;Colorado;Connecticut;Indiana;Iowa;	Montana;Tennessee;Texas;Utah;Virginia.
Right to portability	You can request all the Personal Data You provided to Us and request to transfer Data to another controller.	California;Colorado;Connecticut;Indiana;Iowa;	Montana;Tennessee;Texas;Utah;Virginia.
Right to opt out of sales	The right to opt out of the sale of Personal Data to third parties.	California;Colorado;Connecticut;Indiana;Iowa;	Montana;Tennessee;Texas;Utah;Virginia.
Right to opt out of certain purposes	The right to opt-out of Processing for profiling / targeted advertising purposes.	Colorado;Connecticut;Indiana;Montana;	Tennessee;Texas;Utah;Virginia.
Right to opt out of Processing of sensitive Data	The right to opt-out of Processing of sensitive Data.	California.
Right to opt in for sensitive Data Processing	The right to opt in before Processing of sensitive Data.	Colorado;Connecticut;Indiana;Montana;	Tennessee;Texas;Virginia.
Right against automated decision-making	A prohibition against a business making decisions about a consumer based solely on an automated process without human input.	California;Colorado;Connecticut;Indiana;Iowa;	Montana;Tennessee;Texas;Virginia.
Private right of action	The right to seek civil damages from a Controller for violations of a statute.	California.
Please note! Some states do not have privacy laws. The rights of residents of such states are governed by U.S. federal law. If Your state is not on the list, please contact Us at dpo@highfigure.net.

Access to specific Data and the right to transfer Data

With certain exceptions, if You are a resident of the state of California, USA, You have the right to request a copy of the Personal Data (defined as “Personal information” for the purposes of this section) We have collected about You in the 12 (twelve) months prior to Your request. After receiving Your request and establishing Your identity, We will inform You of:

– categories of Personal information that We have collected about You;

– Our business or commercial purpose for collecting such Personal information;

– categories of third parties with whom We share this Personal information.

Non-discrimination

We will not discriminate against You for exercising Your rights related to the Processing of Your Personal information, as well as Your right to refuse to receive Our Services in the future, or for refusing to receive further marketing, informational / advertising materials from Us.

Do not sell my Personal information

California residents have the right under the California Consumer Privacy Act to opt out of the “sale” of their Personal information by a company governed by CCPA. We do not and will not “sell” Your Personal information, but We recognize that the CCPA defines “Personal information” in such a way that providing access to identifiers associated with You may be considered a “sale”. In the event that these Site visitor identifiers and inferences may be identified as a sale under the CCPA, please use the “Do not sell my Personal information” setting on the Site’s home page. After receiving Your request through the “Do not sell my Personal information” setting, the Company makes a corresponding entry in its database of Personal information / Site Users, which indicates that the Company is aware of the impossibility of further selling Your Personal information. Also, if You would like to record Your preference that We will not “sell” Your Personal information in the future, please contact Us via dpo@highfigure.net.

We generally do not collect information that is considered sensitive Personal information (as defined under the CCPA). In the limited circumstances that We do, such as the collection of Your username and password, We do not collect this information for the purpose of inferring characteristics about You.

12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country You reside in.

Australia and New Zealand

We collect and Process Your Personal Data under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (“Privacy Act”).

This Privacy Policy satisfies the notice requirements defined in both Privacy Acts, in particular: what Personal Data We collect from You, from which sources, for which purposes, and other recipients of Your Personal Data.

If You do not wish to provide the Personal Data necessary to fulfill their applicable purpose, it may affect Our ability to provide Our Services, in particular:

offer You the products or Services that You want;
respond to or help with Your requests.

At any time, You have the right to request access to or correction of Your Personal Data. You can make such a request by contacting Us by using the contact details provided in the section “HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?”

If You believe We are unlawfully Processing Your Personal Data, You have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand’s Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

If You are unsatisfied with the manner in which We address any complaint with regard to Our Processing of Personal Data, You can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa)

General inquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

Additional information for residents of Ukraine

The conditions of this section apply only to residents of Ukraine, which is contained in the Privacy Policy and relates to specific requirements, in accordance with the provisions of the legislation of Ukraine, in particular, the Law of Ukraine “On Personal Data Protection” №2297-VI dd. 01.06.2010.

Each User’s personal non-proprietary rights regarding Personal Data are inalienable and inviolable.

The User, resident of Ukraine, has the following rights in relation to the provided Personal Data:

– to know about the sources of collection, location of the provided Personal Data, purposes of their Processing, and location of the Company;

– to receive information about the conditions for providing access to Personal Data, in particular, information about third parties to whom Your Personal Data is transferred;

– to access his / her Personal Data;

– to receive, no later than 30 (thirty) calendar days from the date of receipt of the request, except in cases provided for by law, a response on whether his or her Personal Data is Processed, as well as to receive the content of such Personal Data;

– to submit a reasoned request to the Controller with an objection to the Processing of his / her Personal Data;

– to submit a reasoned request to change or destroy his / her Personal Data by the Company if this data is processed illegally or is unreliable;

– to protect his / her Personal Data from unlawful Processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protect against the provision of information that is inaccurate or discrediting the honor, dignity and business reputation of the User;

– to file complaints about the Processing of Personal Data to the Ukrainian Parliament Commissioner for Human Rights or to the court;

– to apply legal remedies in case of violation of the legislation on the protection of Personal Data;

– to make warnings regarding the restriction of the right to Process his / her Personal Data when giving Consent;

– if We Process Your Personal Data on the basis of the User’s prior Consent to this Processing – to withdraw the Consent to the Processing of Personal Data, after which such Processing will cease;

– if the Personal Data is exclusively processed automatically, including profiling, which may have legal consequences for the User – to receive protection from an automated decision.

In order to exercise any of the above rights, the User shall contact the Company in writing at the following e-mail address: dpo@highfigure.net.

The Subject of Personal Data is obliged to submit a request for access to Personal Data to the Controller, in accordance with the requirements provided for in part 3 of article 16 of the Law of Ukraine “On Personal Data Protection” №2297-VI dd. 01.06.2010. The period for examining the request for its satisfaction will not exceed 10 (ten) business days from the date of its receipt. During this period, the Controller will inform the User submitting the request that the request will be granted, or the relevant Personal Data will not be provided, indicating the grounds specified in the relevant regulatory legal act. The request shall be satisfied within 30 (thirty calendar days from the date of its receipt, unless otherwise provided by law.

The Controller will notify the Ukrainian Parliament Commissioner for Human Rights of the Processing of Personal Data that poses a particular risk to the rights and freedoms of Personal Data Subjects within 30 (thirty) business days from the date of commencement of such processing.

Additional information for residents of Canada

This section applies only to residents of Canada. The Company Processes Personal Data in accordance with the Personal Information Protection and Electronic Documents Act, Personal Information Protection Act of British Columbia, Personal Information Protection Act of Alberta, and Act respecting the protection of personal information in the private sector of Quebec have the right to interact with its data directly or through a request to Us regarding privacy issues.

This section describes the privacy rights of Canadian residents and how they can exercise them:

Right	Description
Right to access	You can request an explanation of the Processing of Your Personal Data.
Right to rectification	You can change the Data if it is inaccurate or incomplete via request or profile settings on the Site.
Right to delete	You can send Us a request to delete Your Personal Data from Our systems or delete Your account via Site settings. We will remove all Data unless some of them We have to store in compliance with the law requirements.
Right to Data portability	You can request all the Personal Data You provided to Us and request to transfer Data to another controller.
Right to object opt-out	You may object to the Processing of Your Personal Data.
Right to withdraw Consent	You can withdraw Your Consent at any time.
Right not to be subject to automated decision-making	You can object to being subject to automated-based Processing to know if there are consequences of them due to such Processing.
Right to lodge a complaint	If Your request is not satisfied, You can file a complaint to the regulatory body.

To exercise Your rights, contact Us at the following e-mail address: dpo@highfigure.net. We have 30 (thirty) days to exercise Your request from the moment it is received on Our contact email.

We have the right to extend the 30-day period for providing an answer to the request for another 30 (thirty) days in the event that:

failure to respond within the initial 30 (thirty) days may be considered unreasonable interference with Our business;
We need additional time for consultation;
We need additional time to convert the Personal Data into a format that is easy to read.

You have the right to file a complaint with the Office of the Privacy Commissioner of Canada (OPC) if We do not respond to Your request within the first 30 (thirty) days.

In the event of a leak of Your Personal Data, We will promptly notify You of such a case and the degree of threat to Your Personal Data. In accordance with PIPEDA, We will immediately notify the Office of the Privacy Commissioner of Canada (OPC) and keep a record of the leak that has occurred.

We may disclose Personal Data to third-party service providers and related corporations located outside of Canada for the purposes described in the Policy. The Policy requires that the Company share Your Personal Data abroad in a manner that requires the highest standards of confidentiality and security when transferring Personal Data abroad. Please note that when Personal Data is transferred abroad, it may be accessed by courts, law enforcement agencies, and national security agencies. Before disclosing Personal Data, We will assess possible risks that may adversely affect the protection of Personal Data. We ensure the appropriate level of integrity and protection of Personal Data when transferred to third parties, which is required by the provisions of PIPEDA, by entering into agreements with such companies, which provide for the limitation of the use of Personal Data by the third party solely for the purposes provided for in the agreement.

13. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

In Short: Yes, We will update this Privacy Policy as necessary to stay compliant with relevant laws.

We have the right to make changes to this Policy at any time and for any reason by posting a new version of the Policy at the above link. We strongly recommend that You check the Policy and the date of the last change from time to time to stay informed of the latest changes.

If You do not agree with any changes made to the Policy, You must stop using the Site, and You can also request the deletion of Your Personal Data.

If there are material changes to the Policy or the Site that affect Your data privacy rights, We will notify You by displaying information on the Site and, if necessary, ask for Your Consent.

14. DISPUTE RESOLUTIONS

The Privacy Policy shall be governed by and construed in accordance with the applicable laws of Ukraine.

All disputes and disagreements that may arise in connection with the Privacy Policy shall be resolved by the parties through negotiations in compliance with the pre-trial dispute resolution procedure. The pre-trial dispute resolution procedure is mandatory. All claims, suggestions, and comments shall be considered by the Company in writing and sent to the Company’s e-mail address, namely: dpo@usbonet.com, within 30 (thirty) days from the date of sending the letter by You.

In case of failure to resolve disputes through negotiations, any disputes, disagreements, or conflicts between the parties regarding any matters arising out of or related to the Privacy Policy shall be finally settled in accordance with the applicable laws of Ukraine.

If a dispute under the Privacy Policy or in connection with it arises between the Company and You who is under foreign jurisdiction and/or is a citizen of a foreign country, such dispute shall be finally settled by the International Commercial Arbitration Court at the Ukrainian Chamber of Commerce and Industry in accordance with its Rules. The arbitral tribunal shall consist of a sole arbitrator. The seat of the Arbitration Court shall be in Kyiv. The language of the arbitration shall be English.

15. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?

If You have questions or comments about this Privacy Policy, You may email Us at dpo@usbonet.com or contact Us by post at: Inzhenera Preobrazhenskoho Ave 7, Zaporizhzhia 69097, Ukraine.

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of Your country, You may have the right to request access to the Personal Data We collect from You, change that Data, or delete it. To request to review, update, or delete Your Data, please fill out and submit a data subject access request.

Updated on 21/04/2024