Application Privacy Statement
Effective Date: May 28th, 2020


This privacy statement (“Privacy Statement”) applies to the treatment of personally identifiable information submitted by, or otherwise obtained from, you in connection with the associated applications provided by INGVAR COMPANY LTD (and may be provided by INGVAR COMPANY on behalf of a INGVAR COMPANY licensor or partner (“Application Partner”). By using or otherwise accessing the applications, you acknowledge that you accept the practices and policies outlined in this Privacy Statement.
By clicking the “I Agree” button or by using the Services, you are agreeing to be bound by the Privacy Policy.

1. PERSONAL INFORMATION WE COLLECT
We collect your personal information in the following circumstances:
    •    to register for the Services, we may collect your name, email address, state/province and country of residence, zip/postal code, birthdate and gender;
    •    if you connect the Services to a social media account, such as Facebook, we collect your name, email address, profile picture, age range, gender and other information you make public on Facebook, in addition to your friend list (unless you affirmatively revoke such collection);
    •    we collect your geolocation data when you use the Services, which we associate with your personal and anonymous information;
    •    if you create an account with the Services, or connect the Services to a social media account, such as Facebook, your personal information may be linked to otherwise anonymous information collected in accordance with the Privacy Policy, such as how you use the Services or items you purchased at online stores associated with the Services; and
    •    if you contact us for customer service, we may collect your email address, first and last name and, if required, Facebook information, and associate this personal information with anonymous information, such as information about your device.
Please note that while the Services may allow you to visit as a guest and remain anonymous, you may not be able to access all content and features without providing personal information.

2. ANONYMOUS INFORMATION WE COLLECT

We collect anonymous information from you, which may be provided to us by a third party, including but not limited to:

Please note that while your computer or mobile device may allow you to turn off the collection of some of the above information, you may not be able to access all content and features on the Services.


3. HOW WE USE YOUR INFORMATION
We use your personal and anonymous information internally for purposes that include:
    •    to provide the Services to you, such as hosting and displaying information, providing updates, developing, improving or expanding the Services and addressing technical issues;
    •    to generate and analyze information about our users so we can better understand them and how they use the Services and draw trends and predictions based on this information;
    •    to serve you advertisements, provided by INGVAR COMPANY or third parties, on the Services, as well as for marketing and promotional purposes;
    •    to send Service-related push notifications to your device;
    •    to establish and maintain your account on the Services and to protect the security of your account;
    •    to provide customer support or to resolve customer issues;
    •    to inform you of changes to the Services, such as outages, suspensions or other material changes, which could occur through email or a push notification sent to your device; and
    •    if you signed up for any INGVAR COMPANY newsletter, to contact you by email for INGVAR COMPANY news, promotional purposes or market research and that you may opt-out of by clicking an opt-out link located in such an email.

4. INFORMATION DISCLOSURE
We disclose your information outside of INGVAR COMPANY for the following purposes:
    •    we disclose your information to third parties who provide services on our behalf, as described in the Privacy Policy;
    •    for internal INGVAR COMPANY purposes, we may disclose your personal and anonymous information to our parent companies, affiliates, subsidiaries and contractors;
    •    we disclose your information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, other suspected illegal activities or as otherwise may be required by applicable law or, as we deem necessary in our sole discretion, in order to protect the legitimate legal and business interests of INGVAR COMPANY; and
    •    in the event of, or in preparation for, a change of ownership or control of INGVAR COMPANY, a business transition, such as the sale of some, or all, INGVAR COMPANY assets, or the bankruptcy of INGVAR COMPANY, we may disclose and or assign your personal and anonymous information to third parties who will have the right to continue to use such information in the manner set forth in the Privacy Policy.

5. THIRD PARTY SERVICES
We use third parties, who we share your information with and who may collect information from you to assist us with, for example, serving advertisements, fulfilling a purpose you requested of us (for example, billing services), customer support and feedback, analyzing Services functionality and technical issues, sending useful notifications to user devices, tracking use of the Services and generating reports and data models that we use to improve the Services. These third party services may be embedded into the Services, such as through an API or SDK (https://www.appodeal.com/home/privacy-policy/), or may take the form of tracking technologies, such as cookies, web beacons and clear gifs, (“Tracking Technologies“) which enable these third parties to collect information on our behalf.
Information collected by third parties is governed by the applicable third party privacy policy, which may provide for broader information collection than collected by INGVAR COMPANY. These third parties may use your information internally and disclose your information to others and we strongly recommend that you read each third party privacy policy carefully before providing your information.

6. ADVERTISING
The Services may contain advertisements served by third parties. These advertisements use Tracking Technologies to collect information about you, for example, demographics, location and device information, in order to serve you appropriate advertisements and to recognize your device each time a third party serves you an advertisement. Based on this information, third parties may be able to resolve your identity across multiple devices, for example, matching your IP address across multiple devices, in order to target advertisements to you based on your online behavior. This information is collected, used and disclosed in accordance with the terms of the applicable third party privacy policy, as described in section 5 above.
You may be able to opt-out of mobile behavioral advertising by accessing the settings on your Apple or Android device and selecting the appropriate advertisement tracking settings.

7. COOKIES
A cookie is a file that is sent by a service through your browser to your computer, if your browser is enabled to accept cookies, in order to store certain information on your computer and communicate with a service while you are online. Internet browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies or receive a warning before a cookie is stored. You should refer to your browser instructions or “Help” screen to learn more about how to manage cookies. Please note that, if you block cookies, some portions of the Services may not function properly.

8. CALIFORNIA DO NOT TRACK DISCLOSURE
Do Not Track, or DNT, is a web browser setting that requests that a web application disable its tracking of you. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, advertising networks, plug in providers and other web services you encounter while browsing to stop tracking your activity. Currently, there is no DNT technology standard and, as a result, the Services do not respond to DNT signals.

9. CALIFORNIA “SHINE THE LIGHT” RIGHT
If you are a California resident, California Civil Code Section 1798.82 grants you the right to request INGVAR COMPANY’s disclosure of the categories of personal information we provided to third parties, and the names and addresses of these third parties, for direct marketing purposes during the preceding calendar year.
Please note that you may only make this request once per year.

10. ACCESSING OR CHANGING INFORMATION YOU PROVIDED TO US
You may contact INGVAR COMPANY to obtain a copy of any personal information we have collected about you, the production of which may be subject to a fee as permitted by applicable law. In addition, you may contact INGVAR COMPANY to correct or delete such information, except to the extent that retention is necessary for our legitimate business purposes, required by applicable law, in the control of a third party or where correction or deletion is not technically feasible.

11. INFORMATION STORAGE AND RETENTION
While INGVAR COMPANY is a Ukrainian company, the data you provide through the Services is stored and processed by third parties in countries around the world. You authorize INGVAR COMPANY and third parties acting on INGVAR COMPANY’s behalf to use and process your data in any country of their choosing, which may cause your data, including personal and anonymous information, to be subject to privacy protections and legal rights that may not be equivalent to those in your country.

12. INFORMATION FOR EUROPEAN UNION PERSONS
For persons in European Union countries, terms such as “personal information” as used herein refer to “personal data” as defined by the Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data. We will not collect any personal data from you unless you provide it under the terms of the Privacy Policy. By using the Services, you agree that we may transfer your personal information outside the European Union in connection with the purposes stated in the Privacy Policy. Your personal data will be transferred to the United States (and/or other non-EU jurisdictions, as applicable).

13. If you are UNDER THE AGE OF 13
INGVAR COMPANY complies with the U.S. Children’s Online Privacy Protection Act and all other applicable laws and regulations concerning children and the Internet. If you are under the age of 13, you may not create an account on or use the Services. INGVAR COMPANY will not knowingly collect, maintain, or disclose any personal information from children under the age of 13.

14. If you are BETWEEN THE AGE OF 13 AND 18
If you are between the age of 13 and 18, please have your parent or guardian read the Privacy Policy and get his or her permission before you provide any personal information and before you sign up for or use the Services. Never tell anyone online anything private about yourself or your family, including your phone number and address, unless your parent or guardian has approved. Understand that certain social media platforms that you use to access the Services may have this information visible. Use screen names whenever possible to protect your identity. Some areas of the Services may have special rules for children under the age of 18. When you are in those areas, you must follow those rules.

15. INFORMATION FOR PARENTS/GUARDIANS
INGVAR COMPANY encourages parents and guardians to spend time online with their children to become familiar with the types of content available on the Internet, including our Services. Parents and guardians should regularly oversee their children’s use of e-mail and other online communications and transactional features. Control tools are available from online services and software manufacturers that can help provide a safe online environment for kids.
If you are a parent or guardian who has discovered that your child has submitted his or her personal information without your permission or consent, INGVAR COMPANY will take reasonable steps to remove that information from the INGVAR COMPANY database at your request.

16. SECURITY
While INGVAR COMPANY takes precautions against possible breaches in the Services, no website, application or Internet transmission is completely secure. For example, INGVAR COMPANY employs a security technology known as a secure-socket-layer, or SSL, to protect the transmission of critical account information through the Services. However, INGVAR COMPANY cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Your use of the Services is at your own risk. INGVAR COMPANY urges you to take steps to keep your personal information safe by memorizing your password or keeping it in a safe place (separate from your account information), logging out of your account and closing your web browser.

17. UPDATES
INGVAR COMPANY reserves the right, at its sole discretion, to change or modify or to add or remove portions of the Privacy Policy at any time (“Updates“).

18. CONTACT US
 If you have any questions or concerns regarding privacy, please send us a detailed message at contact@ingvar.co. We will make every effort to resolve your concerns.


INGVAR COMPANY LTD Williams st. 66a, Odessa, 65089, UKRAINE.
All personal information you provide via email or mail concerning the Privacy Policy or INGVAR COMPANY’s information collection practices will be kept confidential.