Privacy Policy

Version 1.0

Effective Date: 14.02.2024

Welcome to our website https://28software.com/ (the “Site”). The Site provides some information about our services and business activity and is created for information purposes by 28software (“we,” “28software,” “Company”).
We will be transparent with you about why and how we collect data.
PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE SITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY ALL THE TERMS OF THIS PRIVACY POLICY. BY ACCESSING OR USING OUR SITE, YOU SIGNIFY YOUR UNDERSTANDING OF THE TERMS SET OUT HEREIN.

We are committed to respecting and protecting the privacy of the Personal Data we obtain from you through our Site and we have created this Privacy Policy to inform you about how we collect, use and share your Personal Data, and about our privacy practices in general.

Our Site uses cookies and similar technologies. For more information please read the Cookies section below.

We are always ready to address your questions and concerns regarding this Policy and our privacy practices. If you would like to contact customer service, please contact us at the email address at the end of this Policy.

We continually strive to find new ways to enhance your experience with the Site and we may modify this Privacy Policy from time to time to reflect changes in our privacy practices. You are encouraged to review this Privacy Policy periodically and to check the “Last Updated” (”Effective Date”) date at the top of the Privacy Policy for the most recent version. If we make changes to this Privacy Policy, we will notify you here and in our sole discretion, via notice through the Site or email.

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. You can also click here to go directly to our table of contents.

What personal information do we process?

When you visit, use, or navigate our Services, we may process personal information depending on how you interact with 28software and the Site, the choices you make, and the features you use. For more information please read the Data Processing section below.

Do we process any sensitive personal information?

We do not process sensitive personal information.

Do we receive any information from third parties?

We do not receive any information from third parties.

How do we process your information?

We process your information to provide, improve, and administer our Site, communicate with you, for security, and comply with the law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. For more information please read the Use of the Personal and Usage Data that We Collect section below.

In what situations and with which parties do we share personal information?

We may share information in specific situations and with specific third parties. For more information please read the Disclosure of the Personal Data section below.

How do we keep your information safe?

We have organizational and technical processes and procedures in place to protect your personal information. 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, and or modify your information. For more information please read the Security section below.

What are your rights?

Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information For more information please read the Your Privacy Rights section below.

How do I exercise my rights?

The easiest way to exercise your rights is by filling out our data subject request form available here, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Data Processing

The Personal Data we gather from you helps us communicate with you, suggest relevant information and marketing materials, perform our contract with you and comply with applicable laws, and learn about your visit to the Site. We use this information to improve the Site, to better tailor the features, performance and support of our products and services, to answer your requests, questions and concerns, and to offer you additional information and opportunities. Thus, we use your Personal Data for business purposes.

“Personal Data” is any information that allows us (or others) to identify a person and would include (for example) your name, username, address, email address, IP address or phone number, location, image, as well as other non-public information that is associated with or directly linked to such information.

Non-personal “Usage Data” is anonymous data about your use of the Site that is tied to your computer and/or device through which you use the Site.

Personal Data that We May Collect

We only collect and use your Personal Data when we have a legitimate reason for doing so. In this instance, we only collect Personal Data that is reasonably necessary to provide our services to you.

28software collects information about you, including information that directly or indirectly identifies you. 28software also collects information about how you use the Site. There are also several opportunities for you to share information about yourself and your activities with 28software. Some examples are listed below.

Usage information. We collect information about your online behavior when you use the Site using cookies and third-party services as described below.

Contact information. If you choose to provide us with your contact information (name, email address, etc.), for example by emailing us or subscription, we will use this to respond to support requests, information newsletters and advertisements.

Business, career and education. We may collect, process and store personal data about your career, work experience, workplaces, education, and skills, that is contained in your CV, the letters and messages you send us voluntarily, as well as information published by you in public sources (social and business networks, websites).

Use across our sites and services. We may combine information we collect from you with information obtained from other users, third parties and information legally derived from any other site or mobile application (our or third-party), or service we provide.

Technical information. We collect technical information from the devices and browsers you use to access 28software. This information is used to analyze trends and protect and secure 28software. The information collected includes network information; including operating system, browser, IP addresses, location, timestamps, log files, etc.

Use of the Personal and Usage Data that We Collect

We use, process, and store your Personal Data as necessary to perform our contract with you and for our legitimate business interests, including:

  • – To help us provide and administer our Site, provide personalized user features and access, conduct research, develop new features, and improve the features, algorithms, and usability of our Site.
  • – To communicate with you about your use of our Site, product announcements, and software updates, as well as respond to your requests for assistance.
  • – To communicate with you during the recruiting process and to fulfill our obligations to you as a member of the Referral Program “Invite a Friend”.
  • – Communication with you on the subject of partnership and cooperation with 28software, the project you wrote about through the contact form on the Site.
  • – To show and/or send you direct marketing emails and special offers, new features about 28software, from which you can unsubscribe at any time.
  • – To calculate aggregate statistics on the number of unique devices using our Site, and to detect and prevent fraud and misuse of those.
  • – To comply with applicable laws, and regulations and respond to the lawful requests of the competent authorities.

Usage Data may be used by us for administrative, analytical, research, optimization, security and other purposes. Specifically, we may use your Usage Data to help us learn more about your activities, personalize your content, compile statistics, respond to customer service inquiries, provide security and otherwise enhance your experience. Usage Data may also be used to help us provide you with advertising that better suits your interests.

Geolocation information will be used to determine the jurisdiction in which you’re located so we can determine what set of laws or restrictions apply to you.

Your device ID may be used to track your usage of our Site so that we can better understand your preferences and tendencies which will help us best personalize your experience and provide you with offers and notifications that are tailored to you.

Service Providers

We may employ third party companies and individuals to facilitate our Site (“Service Providers”), provide services on our behalf, perform service-related services or assist us in analysing how our Site is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Site.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Site. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

We also encourage you to review Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

Cookie Settings

We may use third-party Service Providers to manage the cookie settings of our Site.

EasyCookie

EasyCookie is a web-based service for cookie consent management.

Personal information that may be collected when using this service is processed in accordance with the Privacy Policy available at https://app.easycookie.io/privacy-policy.

Data Storage and Retention

We take measures to delete your Personal Data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it unless we are required by law to keep this information for a longer period. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, mandatory retention periods provided by law and the relevant statute of limitations.

Transfer of Data

The Personal Data we collect is stored and/or processed in Ukraine, where we or our partners, affiliates, and third-party providers maintain facilities.

We may share your Personal Data, including Personal Data that identifies you personally, with any of our parent companies, subsidiary companies, affiliates or other trusted related entities.

The countries to which we store, process, or transfer your Personal Data may not have the same data protection laws as the country in which you initially provided the information. If we transfer your Personal Data to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred Personal Data in accordance with this Privacy Policy.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Disclosure of the Personal Data

We may transfer your Personal and Usage Data to our affiliated entities, but such information shall continue to be governed by this Privacy Policy.

Except as otherwise stated in this Privacy Policy, we do not trade, rent, or share your Personal Data with third parties and we will not disclose financial information that is part of your Personal Data unless you ask us to do so.

We may share your Personal Data with third parties to provide you with the products and services that we offer you through the Site for payment processing, shipping and distribution processing, account inquiries, and marketing analytics. These third parties are required not to use your Personal Data other than to provide the products and services requested by 28software and are bound by confidentiality agreements about their use of such information.

You expressly consent to the sharing of your Personal Data with our contractors and third-party service providers to provide products, services and interest-based advertising to you.

Usage Data in aggregated, anonymous form may be shared with third parties who assist us with our internal operations such as administration, analytics, research, and optimization.

If another company acquires our company or our assets, that company will possess the Personal Data collected by us and it will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

Regardless of any choices you make regarding your Personal Data (as described below), we may disclose your Personal Data if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on 28software; (b) to protect and defend the rights or property of 28software, or others; (c) lawful requests by public authorities, including to meet national security or law enforcement requirements; (d) take action against illegal activity, suspected abuse; (e) unauthorized use of the Site.

In some cases, your information (publications, link shares, comments) and content may be publicly accessible.

Cookies

We use cookies (a cookie is a small text file which is placed onto your device) and other online tracking devices such as web beacons, and single-pixel gifs on this Site to:

  • – recognise you whenever you visit this Site;
  • – obtain information about your preferences, online movements and use of the internet;
  • – carry out analysis to help improve our content and to better understand our customer and visitor requirements and interests; and
  • – target our marketing and advertising campaigns and those of our partners more effectively.

In most cases, we will need your consent in order to use cookies on this Site. The exception is where the cookie is essential in order for us to provide you with a service you have requested (e.g. to enable us to offer you a product, service, offer, reward or promotion for which you are applying, or have applied, for).

We work with third-party suppliers who may also set cookies on our Site, for example, LinkedIn Pixel, Facebook Pixel, HubSpot Tracker and Google Tracking Pixel. These third-party suppliers are responsible for the cookies they set on our site. If you want further information please go to the Site for the relevant third party.

Managing Cookies

We strive to give you choices about how your Personal Data is used. We do not sell, trade, or otherwise transfer the information we collect from you to unaffiliated third parties. We do, however, share the information we collect from you with trusted third parties who assist us in operating our Site, and conducting our business, provided that those parties agree to keep your information confidential and secure.

Most browsers allow you to refuse to accept cookies and delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

Blocking all cookies will have a negative impact on the usability of many websites.

If you block cookies, you will not be able to use all the features on our Site.

For more information please visit https://www.aboutcookies.org/

Your Privacy Rights

By providing Personal Data to us, you understand we will collect, hold, use, and disclose your Personal Data in accordance with this Privacy Policy. You do not have to provide Personal Data to us, however, if you do not, it may affect your use of our Site offered on or through it.

If you have previously agreed to us using your Personal Data for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Upon request, 28software will provide you with information about whether we hold any of your Personal Data. You may access, correct, or request deletion of your Personal Data by contacting us at  info@28software.com. We will respond to your request within a reasonable timeframe.

Please note, that this right is subject to certain exceptions, including if we need to comply with a legal obligation or complete a transaction for which we collected the information.

28software acknowledges that you have the right to access your Personal Data.

We will not discriminate against you for exercising any of your rights over your Personal Data. Unless your Personal Data is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.

To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this Privacy Policy, or opt out using the opt-out facilities provided in the communication.

You have the right to access information held about you. You also have the right to ask us to update and correct any out-of-date or incorrect personally identifiable information that we hold about you free of charge.

Please note that we will try to verify your identity via the email address or other information such as the phone number that is associated with your request before deleting your Personal Data. If another person makes this request on your behalf, please note that we will verify your identity and require them to prove that they have your written authorization to request on your behalf.

Legal Bases for Processing Your Personal Data

We will only collect and use your Personal Data when we have a legal right to do so. In this case, we will collect and use your Personal Data lawfully, fairly, and in a transparent manner. If we seek your consent to process your Personal Data, and you are under 18 years of age, we will seek your parent or legal guardian’s consent to process your Personal Data for that specific purpose.

Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:

Consent From You

Where you give us consent to collect and use your Personal Data for a specific purpose. You may withdraw your consent at any time using the facilities we provide; however, this will not affect any use of your information that has already taken place. You may consent to provide your email address for the purpose of receiving marketing emails from us. While you may unsubscribe at any time, we cannot recall any email we have already sent. If you have any further enquiries about how to withdraw your consent, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

Performance of a Contract or Transaction

Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, if you contact us with an enquiry, we may require Personal Data such as your name and contact details in order to respond.

Our Legitimate Interests

Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.

Compliance with Law

In some cases, we may have a legal obligation to use or keep your Personal Data. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further inquiries about how we retain Personal Data in order to comply with the law, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

International Transfers Outside of the European Economic Area (EEA)

We will ensure that any transfer of Personal Data from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Your Rights and Controlling Your Personal Data

Restrict:

You have the right to request that we restrict the processing of your Personal Data if (i) you are concerned about the accuracy of your Personal Data; (ii) you believe your Personal Data has been unlawfully processed; (iii) you need us to maintain the Personal Data solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.

Objecting to processing:

You have the right to object to the processing of your Personal Data that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your Personal Data.

Data portability:

You may have the right to request a copy of the Personal Data we hold about you. Where possible, we will provide this information in CSV format or another easily readable machine format. You may also have the right to request that we transfer this Personal Data to a third party.

Deletion:

You may have a right to request that we delete the Personal Data we hold about you at any time, and we will take reasonable steps to delete your Personal Data from our current records. If you ask us to delete your Personal Data, we will let you know how the deletion affects your use of our Site or products and services. There may be exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. If you terminate or delete your account, we will delete your Personal Data within 30 days of the deletion of your account. Please be aware that search engines and similar third parties may still retain copies of your Personal Data that have been made public at least once, like certain profile information and public comments, even after you have deleted the information from our services or deactivated your account.

Our Policy on “Do Not Track” Signals

We honor Do Not Track signals and do not track plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Minors

While the Site may be visited by children, we do not knowingly collect or use any Personal Data from children under the age of 18 and hereby specifically prohibit any user under the age of 18 from providing us with any Personal Data. If you are a parent of a child under 18 years of age and you believe your child has provided us with Personal Data, please contact us at  info@28software.com and we will delete the information from our IT system.

We may collect a device ID or other persistent identifier linked to the device or computer that may be used by a child to use our Site. The data collected will be anonymous and not tied to any Personal Data. In addition, this data will be used solely for internal purposes such as personalization of content, security, and contextual (not behavioural) advertising.

If you are below 18, please obtain your parents’ or guardians’ permission before providing us with any Personal Data.

Security

It is entirely your choice whether or not you provide Personal Data to us. We and/or our third-party partners have put in place physical, electronic, and managerial procedures to attempt to safeguard and help prevent unauthorized access, maintain data security and correctly use the Personal Data collected through the Site. We take or obligate applicable third parties to take, reasonable precautions to protect our customers’ Personal Data against loss, misuse, unauthorized disclosure, alteration, and destruction.

However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Data, we cannot ensure or warrant the security of any information that you transmit to us or from us, and you do so at your own risk. We cannot ensure or warrant the security of any information you transmit to us by email and you do so at your own risk.

If there is a breach of security involving your Personal Data from our Site, we will inform you immediately and take commercially reasonable steps to rectify such breach.

If you believe your Personal Data is being improperly used by us or any third party, please immediately notify us via email at info@28software.com.

In the event you choose to establish an account with us, you should not share your login information with anyone.

External Sources

Our Site may link to external sites beyond our control. This Privacy Policy covers only the way we treat the Personal Data and Usage Data we collect on our Site. By accessing any external sites, you are agreeing to the privacy policies of those sites.

Please note that the external sites may have different policies for the collection, use and disclosure of your Personal Data. We have no control over and are not responsible for the privacy practices of such third parties. Therefore, you are encouraged to review the privacy policies of all third-party websites or apps. Without limiting anything in the following section, we are not liable in any way for the actions, inactions or policies of any external websites or apps.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

By mail: Warsaw Financial Center Emilii Plater 53, floor 24, 00-113
Warsaw, Poland, or

Dorohozhytska St, 3, Building 9, Kyiv, Ukraine, 04119

By email:  info@28software.com