Privacy & Policy Agreement
Understanding all the responsibility and importance of ensuring the confidentiality of Personal and other data (hereinafter – Data), the Private enterprise “GetGrant” concludes this Confidentiality Agreement (hereinafter – the Agreement) with you (hereinafter – the User) to determine the order of receipt, storage, processing, use and disclosure of User Data when using the Website https://getgrant.eu (hereinafter – the Website).
To use the Website and the services provided on the Website, the User must agree to the Terms of this Agreement. A user who does not agree to the terms of the Agreement has no right to use the Website and the services offered on the Website.
A user who has not reached the age established by law to conclude such Terms and Conditions has no right to use the Website, services, and services on the Website.
1. SCOPE AND CONSENT
1.1. The personal data of users of the Website are processed by the Private Enterprise “GETGRANT”, a legal entity registered under the legislation of Ukraine, with its location at the address: 23 Oleny Stepanivny str., Apt. 19, Lviv, Ukraine, 79016 (hereinafter – the Company).
1.2. The Company is the owner and administrator of the personal database of users of the Website (hereinafter – the Database).
1.3. Website user data is processed on secure servers within and outside the European Economic Area.
1.4. This Agreement describes the procedure established by the Company for processing Data collected using the Website, the GetGrant mobile application (hereinafter – the Mobile Application), and related services and tools that allow the User to register on the Website and receive Website services or view relevant training programs, seminars, webinars, etc. In all specified cases, the Company processes User Data exclusively within the framework of the Law of Ukraine “On the Protection of Personal Data” requirements and the Convention on the Protection of Individuals in Connection with Automated Processing of Personal Data. This Privacy Agreement is designed in accordance with the provisions of these documents.
1.5. By using the Website, and/or the mobile application, and/or other related services and tools of the Website, the User gives his consent to the Company for the processing of his personal data, such as: the name and surname of the user, the name and type of organization on whose behalf registration of the User’s Account, the User’s gender, the User’s age at the time of registration, country of residence, email address, and other contact information at the user’s request; IP addresses, other user communication data; messages, letters, statements transmitted to the user by other users and vice versa, and also gives his consent to the transfer of his personal data to third parties, including the transfer of personal data abroad, to any third country, in accordance with this Privacy Agreement and the Website User Agreement.
1.6. Users should be aware that when clicking on some links posted on the Website or in the mobile application, they may be redirected to the Websites (with applications, etc.) of other companies outside the hosting space of the Company, where information about Users is collected outside the direct control of the Company. In such a case, the privacy policies of third-party Websites and/or applications will regulate the processing of information received from users by these third parties.
2. INFORMATION COLLECTED, OBTAINED AND POSTED BY THE COMPANY
2.1. Registration information: When the User creates an account on the Website, the Company may request certain information, such as the User’s first and last name, the name and type of organization on behalf of which the User’s Account is registered, the User’s gender, the User’s age at the time of registration, country of residence, valid email address and password. The account includes information about them, such as geographic location, first and last name, and related information, including photos they may upload to their account. Users are responsible for all information they post to public accounts. The User must understand all the risks associated with publishing his address or information about his exact location. If the User decides to enter the Website using the authentication service of a third-party operator, such as information on the Google social network or from Meta services, the Company may receive an additional profile or other information to which access is provided by such a third party.
2.2. Announcements and Agreements. As part of its service, the Company may post information, including personal and contact information, necessary for the execution of transactions between the buyer and the seller, for sending messages, communicating between users, and making payments. All information required to post ads is required to create an account(s). Users are responsible for all information posted by them on the Website. The User must carefully understand all the risks associated with the fact that he publishes an address or information of a personal nature.
2.3. Advertising and Promotion. During the Website’s operation, the Company may also process information related to the effectiveness of advertising campaigns, including views of ads on the Website and third-party Websites.
2.4. Customer service. When users contact the customer service department, the Company, if necessary, may, in the course of its Website, collect personal information required to fulfill the User’s request and receive feedback. The Company may also contact the User using the existing contact information of the account(s) provided for this purpose. The Company may also collect other information about communication with Users, such as any support requests submitted by Users or any feedback provided by Users, particularly in the form of feedback left by Users.
2.5. Website and mobile data. The Company may automatically receive and register on its servers information from the user’s browser or any device, including the IP address, geolocation of the User, software and hardware attributes, pages requested by the User, data contained in the browser’s databases, including SQL databases, mobile identifiers (including mobile device identifiers such as Google Advertisement ID, IFA, or IFV), application usage information, and/or information about other devices used, or system-level information. This can happen on the Mobile application website or third-party services. Additional information on how users can control and/or block such information collection is provided below in Section 6 of this policy.
2.6. Information obtained as a result of surveys: The Company may collect and store information obtained as a result of surveys that may be conducted by the Company or by contractors engaged by the Company – third parties, namely information regarding gender, age, marital status, personal preferences, etc.
2.7. Attached information. The Company may also add information lawfully obtained from business partners or third parties to the Company’s existing data about its users.
2.8. Information available from User profiles in multi-user Internet platforms (social networks). By registering on the Website, or logging in to the Website using the authentication services of social networks, the User gives the Company consent to the collection and processing of information available from the relevant profiles in social networks, as well as to the publication in the relevant social networks of information about the User’s actions on the Website, and/or in the mobile application.
Information that the Company does not collect or process
The Company does not collect or process personal data about racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, and similar information.
3. IP-ADDRESS, COOKIES AND MOBILE IDENTIFIERS
3.1. During the Website’s operation, the Company may collect certain information using technologies such as cookies, pixels, and local storage (as in your browser or mobile device).
3.2. Cookies are small text files that store information directly on the User’s computer, mobile phone, or other device.
3.3. Pixels are small digital images that are part of the code on web pages that allow another server to measure web page views and are often used in conjunction with cookies. The code tracks how, when (and on which page) the pixel is loaded to indicate that the User is interacting with a page or part of a page on the Website.
3.4. With the help of cookies, the web server can save, for example, preferences and settings on the User’s computer, mobile phone or other device(s), which are then automatically restored at the next visit. In other words, cookie files are intended to make the use of the Website more convenient, for example, so that the User does not have to repeat the process of logging into the system during the next visit. The Company uses both persistent and session cookies. Persistent cookies remain on the User’s computer for longer, and session cookies are automatically deleted when the browser window is closed.
3.5. The Company may allow third parties, such as advertising and/or analytics service providers, to collect information using these technologies directly on the Website’s web page or mobile application. The data they collect is subject to protection in accordance with the applicable privacy policies of those third parties.
3.6. We take all necessary measures to prevent any unauthorized access and use of your data. Our employees are responsible for maintaining the confidentiality of your information and will only use it to provide the appropriate services related to your request.
3.7. We do not collect any personal data that could directly identify you (e.g. first name, last name, email address) from our cookies; we simply use the information to provide or advertise our services to you.
3.8. Cookies policy:
3.8.1. By clicking “Accept”, you agree to the use of cookies specified below. Acceptance is related to the browser/computer/device used. Your choice will be recorded in one of our technical cookies and will last for one year.
3.8.2. You can delete this and all other cookies as described on this page.
3.8.3. We are not responsible for using or collecting data by cookies set by third parties, which in some cases may be profiling cookies.
3.8.4. The technology we use to block third-party services that may use cookies is based on JavaScript.
3.8.5. If you have activated any blocking or manipulation of JavaScript code execution in your browser/computer/device, you may not be protected from the blocking of cookies described above. In this case, we recommend you check and eventually block/delete cookies using the methods described on this page (here below) or other tools.
3.9. Manage and delete cookies.
We use the following types of cookies:
3.9.1. Technical cookies are necessary for our Website to function properly. They allow you to enter secure areas of our Website and maintain state between pages. They contain basic personal data (e.g., first name, last name, email address) to which we have access. We do not use this personal data for any purpose other than navigating the Website and using its services. We do not collect this data.
Cookies are also used to record whether you have consented (or not) to the use of cookies on this Website so that you are not asked every time you visit the Website.
3.9.2. Analytical cookies allow us to recognize and count the number of visitors and see how visitors move around our Website when they use it. This helps us improve our Website, for example, by ensuring that users can easily find what they are looking for.
These cookies are set by a third-party service called Google Analytics.
They may contain personal data to which we do not have direct access.
The Company may only use this data in the form of aggregated information (e.g., average age, percentage of visits from each country, browser used).
The information we use through this service is never linked to any personal data.
Without your consent, we have anonymized the IP address, which is unavailable to Google Analytics.
3.9.3. Third-Party Cookies – We also use cookies provided by YouTube or Google Maps (see the next section of this page for more information). These cookies can track personal data.
3.10. Details of how we use third-party services that use cookies
3.10.1. Analytical cookies
The Company’s Website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to help analyze the use of this Website. For this purpose, Google Analytics stores cookies and text files on your computer.
The information generated by cookies about your use of this Website (including your IP address) and information about visitor behavior will be collected and stored by Google. According to the terms of use of Google Analytics, Google will use this information to evaluate your use of the Website and compile reports on Website activity for the Company.
The Company will use the services provided by Google Analytics in a fully aggregated and anonymous manner. We do not have access to any specific personal data.
You can opt out of using Google Analytics cookies by downloading and installing the Google Analytics Opt-out Browser.
3.10.2. Third-party cookies
We use the following third-party services that may set and use cookies on your computer/mobile device.
YouTube -> More Information
Google Maps -> More Information
We do not have access to any personal information. We target interests, behaviors, preferences, and personal data, such as age or nationality, only in aggregate and anonymous form on the Google Analytics platform.
YouTube uses cookies to enable us to use its services to embed videos on our Websites (including live streaming).
Google Maps uses cookies to enable us to use its services to embed maps on our Websites.
3.11. Control or delete cookies
Depending on which web browser you use, it is possible to control the use of cookies or delete existing cookies from your computer.
All modern browsers allow you to change cookie settings. Usually, these settings are found in your browser’s “options” or “settings” menu.
You may find the links below helpful in understanding these settings; otherwise, you should use the Help option in your browser for more information.
Cookie settings in Microsoft Edge
Please note that if you delete or restrict cookies from the Website, you may not be able to fully enjoy some of the features and services offered by this Website, either directly or through third-party services (such as embedded YouTube videos, including live streams), social plugins and web forms).
4. USE OF PERSONAL DATA
4.1. To provide its services, the Company may use the information that the Company collects and places for the following purposes:
4.1.1. providing customer service, including creating and managing user accounts, solving technical difficulties, and accessing various functions;
4.1.2. adaptation of offers and experiences, including advertising on its services or services of third parties;
4.1.3. control of general and individual user activity, such as keyword searches, ad posting, and transaction activity, as well as manage traffic on the Website;
4.1.4. communication with users, including for service, customer service, or permitted marketing communications through any available communication channels;
4.1.5. conducting scientific research and analytical activities to improve the service and services of the Website;
4.1.6. ensuring compliance with the Website User Agreement, taking into account the fight against fraud and insults;
4.1.7. evaluating certain factors of personal information, in particular, to analyze and predict personal preferences, interests, behavior, and location.
4.2. The Company will retain your personal data for as long as necessary to achieve its collected purposes, including to comply with any legal, accounting, or reporting requirements.
To determine the appropriate storage period, the Company takes into account the volume, nature and sensitivity of personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purpose for which the Company processes your personal data, and whether the Company can achieve these goals through other means, and relevant legal requirements.
If your account has been inactive for more than 18 months, we reserve the right to delete your account, including all personal data stored in the account, which means that you will no longer be able to access and use it.
If you have any questions about the data retention period, please contact us via the email listed in the Contact section.
5. INFORMATION EXCHANGE
5.1. The Company may share the information it collects with affiliates (companies under common ownership or common control of the Naspers Group) located in any third country. These companies can only process and use the received personal data for the purposes specified in Clause 4 of this Agreement. At the same time, the transferred Data remain the subject of this Agreement.
5.2. The Company does not share users’ personal information with non-affiliated Parties, except with the appropriate permission of users.
5.3. The Company may use third-party service providers to provide some components of its services, in such cases, the providers are not authorized to use the Data obtained through the Company’s Website other than to provide the Company’s services, and the Data itself is the subject of this Agreement.
5.4. The Company reserves the right, in accordance with the requirements of the law, to exchange information with private individuals and government bodies for the following purposes:
– fight against fraud and abuse on the Website;
– investigation of alleged violations of the law or combating any other alleged violations of the Agreement with users of the Website.
5.5. The Company can provide users’ personal data at the request of competent authorities, issued in accordance with the requirements of current legislation, including in accordance with Art. 93 of the Criminal Procedure Code of Ukraine.
5.6. According to the Privacy Agreement, the Company undertakes not to rent or sell any personal data of the User. If the Company’s business or part of this business is sold or reorganized, and the Company transfers all or substantially all of its assets to a new owner, users’ personal data may be transferred to the buyer to ensure the continuity of the Website.
5.7. The Company may share certain de-identified information (data that does not allow users to be individually identified) to third-party service providers, trusted partners, or authorized researchers to better understand which advertisements or services may be of interest to users, to improve the overall quality and efficiency of services on the Website or services, or to ensure its contribution to scientific research, which, in the opinion of the Company, can bring great social benefit.
5.8. The Company may transfer the information it collects to third parties who provide the Company’s services to conduct research or provide services to Users. In contrast, the data transferred is the subject of this Privacy Agreement. The third parties involved are not entitled to use the information otherwise for providing services to the Company.
5.9. In cases of transfer of personal data provided for in this section 5 of the Privacy Policy, informing the User about the transfer of his personal data remains at the discretion of the Company.
6. USER CONTROL
6.1. Access, Correction, and Removal: Users who have created an account may access, correct, or delete the information they provide. The User is responsible for the accuracy of the data provided.
6.2. If the User’s account was created through an identity provider (for example, Google or Meta), the User can also disable or change the account data through the provider’s identity settings (for example, on facebook.com). The posted information can be changed or deleted in the User’s personal account “My account” on the Website page or in the application. The Company may stop processing the User’s personal data upon receipt of the User’s written notice of withdrawal of consent to the processing of personal data.
6.3. Choice of third parties: Some external entities operating on the Website, such as Google AdWords, allow users to withdraw their consent to collecting and using their data for advertising based on user activity. For more information and options, please visit http://www.networkadvertising.org.
6.4. Other rights of Users in connection with the processing of their personal data by the Company:
6.4.1. to know the location of the Database containing the Data of the Website Users, its purpose and name, the location of the owner and managers of personal data, or to give an appropriate mandate to obtain this information by authorized users of the Website, except in cases established by law;
6.4.2. receive information about the conditions for providing access to Data, in particular, information about third parties to whom the personal data of users of the Website is transferred;
6.4.3. access to your personal data;
6.4.4. to receive no later than thirty calendar days from the date of receipt of the request, except in cases provided by law, an answer about whether his personal data is processed or stored, as well as to receive the content of such Data;
6.4.5. submit a reasoned claim to the Data owner with an objection to the processing of the Data;
6.4.6. make a reasoned demand to change or destroy the Data by the Data owner and/or administrator if the data is processed illegally or is unreliable;
6.4.7. to protect personal data from illegal processing and accidental loss, destruction, or damage due to intentional concealment, failure to provide, or untimely provision of data, as well as protection from providing information that is unreliable or dishonors honor, dignity, and business reputation;
6.4.8. file complaints about the processing of Data to state authorities and officials, whose authority is to ensure the protection of personal data, or to the court;
6.4.9. apply legal remedies in case of violation of Data Protection legislation;
6.4.10. withdraw consent to Data processing;
6.4.11. to know the mechanism of automatic data processing;
6.4.12. to protect against an automated decision that has legal consequences for the Website’s users.
7. SECURITY
7.1. All information we collect is reasonably protected by security measures and procedures to prevent unauthorized access or use of the data. Persons affiliated with the Company, trusted partners, and independent service providers undertake to use the information received from the Company in accordance with our security requirements and this Agreement.
8. DATA PROCESSING AS PART OF DEVELOPER PORTAL SERVICES
To provide services to the Website, we process the Data of our users who are software developers or contractors/employees of such developers (collectively “Developer” or “Developers”). We process the app name, contact person, email address, and phone number for this particular service.
Use of the Website requires activation using Website account data. Each time a Developer adds a new application (“Application”), you must fill out a special form and provide us with additional information related to the Application and a contact person in accordance with the provisions of the Website Terms of Use. Providing us with the necessary data in the requested form is voluntary but necessary for using the Website.
As part of using the Website’s services, we also process data about the activities of the Developers within the Website. We process the above information for the proper performance of the contract you entered into with us, for the improvement of our Services and taking into account our legitimate interest in preventing fraud or abuse, as well as in ensuring compliance with the Addendum to the User Agreement of the Website’s services and services.
The Company is not responsible for the legality of the processing of User Data as part of the Application added by the Developer. The obligation to provide reliable information regarding the rules of use of the Application, the security policy and other information required by the current legislation, in particular the provisions on data protection, rests with each Developer. The Company obliges the Developers to update and maintain the Application, in particular, to ensure the security of user data processed through it, in accordance with the Terms of Use of the Website. To exercise their rights in accordance with the provisions on the protection of personal data, any User using the Application must contact the Developer directly or the organization specified in the relevant document describing the rules for using a particular Application.
9. CHANGES TO THIS POLICY
9.1. This Agreement was last updated on 27/07/2024. The Company may update this Agreement from time to time, the new version of the Privacy Agreement shall enter into force from the moment it is posted on the Internet at the address specified in this paragraph unless otherwise provided by the new version of the Agreement. The current version of the Agreement is always available on the page at the following address: https://getgrant.eu/privacy/.
9.2. If the Company has made any changes to the Privacy Agreement, with which the User disagrees, he/she is obliged to stop using the Website’s services. Continued use of the Website confirms the User’s consent and acceptance of the relevant version of the Agreement.
Approved: August 15, 2023
Modified: August 27, 2024