Privacy Policy

Last updated: 15.06.2022

The Privacy Policy regulates the procedure for ensuring the privacy of personal data.

The provisions of this Privacy Policy describe how Plerdy processes, stores, and collects Personal Data.

We have developed this Privacy Policy to describe how Personal Data is stored and protected, and communicated to the Data Subject.

During the implementation of its activities, the Platform may use your Personal Data in various ways, including when providing the Tools. That is why we have developed this document so that each Data Subject has the opportunity to familiarize himself with the ways in which his Personal Data is used or to decide to refuse such use.

The Platform may disseminate Personal Data during its activities. The Privacy Policy describes Third Parties that may receive your data.

References to the words "you," "you," or "yours" (or similar words in meaning) mean our Data Subject, depending on the context of the Privacy Policy.

The provisions of this Privacy Policy apply only to Personal Data obtained by the Platform in the ways described in its conditions. Plerdy is in no way responsible for processing Personal Data by third parties, including a natural or legal entity, who may receive Personal Data under the terms of this Privacy Policy.

Plerdy operates worldwide. Based on this, the question arises as to which country's legislation should regulate the methods of personal data processing. The most common and fundamental in the world is the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016). Still, it regulates the processing of Personal Data only for residents of the European Union and the European Economic Area. That is why, in our Privacy Policy, we have indicated the primary legislation of those jurisdictions, the provisions of which we are mainly guided by when processing Personal Data. We have also provided conditions for processing Personal Data for the jurisdictions of residents from other countries.

We thank you for using the Plerdy Platform.

1. DEFINITIONS

1.1 Account - is a functional part of the Site, through which the Client has the opportunity to pay for the use of the Platform Tools and can manage the receipt of the Tools.

1.2 Affiliate Program - is an interaction algorithm designed to support marketing, SEO, PPC, CRO, and Growth hacking agencies and increase the number of Users and profits.

1.3 Blog - is an informative part of the Site where Plerdy employees post informative articles and which the Client can comment on.

1.4 Checkbox - means an element of the Site's graphical interface, which allows the Client to provide his Consent. For example: when registering on the Site, when agreeing to the Terms of Use, etc.

1.5 Client - is a legal entity or an individual entrepreneur who registers on the Site, integrates Plerdy on its website, and receives the Tools.

1.6 Controller - means any natural or legal person, government agency, institution, or other body that independently determines the purposes and means of personal data processing.

1.7 Cookies - are a piece of information in the form of text or binary data is transmitted to the browser from the site.

1.8 Client's Consent (hereinafter "Consent") - means a voluntary, specific, informed, and unequivocal expression of will, in which the Client using a statement or explicit affirmative action agrees to the processing of his Personal Data.

1.9 Data Subject - means the common name for the Client and the User.

1.10 Guest Post - is an author's article that the Client has the right to place on the pages of the Blog.

1.11 Personal Data - means any information that directly or indirectly allows identifying the Client and/or the User. For example, name, surname, phone number, IP address.

1.12 Plerdy Platform Site (hereinafter “Site”) - means a web page or group of web pages on the Internet, which are located at: https://www.plerdy.com/, through which the Client receives Tools from Platforms.

1.13 Plerdy Platform (hereinafter referred to as the “Platform” or “Plerdy”) - is a tool that allows to realize the Client's business goals in the field of marketing research, optimize sales and analyze User behavior which increases site conversion rates, and get Tools.

1.14 Products - are the common name of the Client's goods, services, and products.

1.15 Processor - is a natural or legal person, government agency, institution, or other body that processes Personal Data on behalf of and behalf of the Controller.

1.16 Pop-up form - is an element of the Site's interface displayed on top of the Site's web page in a browser and is used to advertise the Product and/or obtain additional information and/or obtain Consent.

1.17 Referral Program - is a cooperation form between Plerdy and the Client, according to the Client has the right to place links to the Site for a fee.

1.18 Terms of Use - means a document that provides terms, rules, and fundamental provisions for the use of the Platform Tools.

1.19 Third Party - means a natural or legal person, government agency, institution, or body other than the Client, User, Controller, Processor, and persons authorized by the Controller or Processor under their direct supervision to process Personal Data.

1.20 Tools - are an algorithm of actions performed by the Platform for the Client in digital marketing to improve the conversion of the site and sales of the Client's Products.

1.21 User - is a natural person or legal entity that interacts with the Client (through its website) and receives products from the Client.

2. GENERAL PROVISIONS

2.1 The Platform processes and stores Personal Data based on the principles of legality, fairness and transparency by Article 5 "Principles relating to processing of personal data" of the GDPR.

2.2 The Platform acts as a Processor for the Personal Data it receives through the Client's use of the Site, the provision of Tools, communication with Plerdy employees, the use of social networks, and messengers.

2.3 The Platform is not responsible for processing Personal Data by third parties that are not controlled or owned by Plerdy.

3. PERSONAL DATA

3.1 The Platform receives the following Personal Data about the Client:

3.1.1 full name;

3.1.2 contacts: e-mail, work and/or contact phone number;

3.1.3 messenger ID;

3.1.4 password required to log in to the Account;

3.1.5 payment data: Plerdy does not collect or process your payment data directly.

3.2 Plerdy purposely does not collect Users' Personal Data. Users' Personal Data is processed and stored by Plerdy in encrypted form.

3.3 Plerdy may obtain User Personal Data only through the use of the Pop-up form.

3.4 In case of using the Pop-up form by the User, Plerdy may receive the following Personal Data of the User:

3.4.1 full name;

3.4.2 contacts: e-mail, work and/or contact phone number, links to social networks and any other types of contacts;

3.4.3 links to profiles on social networks;

3.4.4 address and/or place of residence.

3.5 When you visit the Site or receive the Tools, Plerdy may collect the following Personal Data automatically:

3.5.1 IP address;

3.5.2 time zone and language settings;

3.5.3 browser type and version;

3.5.4 operating system, device type and screen extension;

3.5.5 location country;

3.5.6 Information about your visit to the Site, including complete details on the URL, route to and from the Site (including date and time), page response time, data loading errors, length of stay on certain pages, activity on the page (such information such as scrolling and mouse movements, clicks), methods used to exit the page, and phone numbers for contacting the Client service center.

3.6 Plerdy does not collect or process sensitive Personal Data of users, such as race or ethnic origin, political views, religious or philosophical beliefs, union membership, genetic or biometric data, health information, sexual life or sexual orientation.

3.7 Plerdy has the right to collect and receive Personal Data as follows:

3.7.1 when providing Tools;

3.7.2 during interaction with the employees of the Platform, by exchanging e-mails and telephone calls;

3.7.3 using log files, cookies and other tracking technologies;

3.7.4 by using a feedback form;

3.7.5 through the use of messengers and social networks;

3.7.6 when commenting on Blog articles;

3.7.7 within the Referral and Affiliate Program;

3.7.8 when using the Pop-up form;

3.7.9 when using UX games;

3.7.10 during the User survey, using the NPS (Net Promoter Score) form;

3.7.11 during the information provision by the Client about his business;

3.7.12 by subscribing to receive news from Plerdy;

3.7.13 when posting a Guest Post on the Blog pages.

3.8 During the Affiliate Program, Plerdy receives Client Personal Data through feedback and communication forms between Client and Plerdy employees. During the Affiliate Program, Plerdy may additionally receive Personal Data from Client Users.

3.9 When providing the Tools, the Platform has the right to receive the domain name of the Client's site. And the Client undertakes to provide the domain name of his site when registering on the Site.

3.10 During the Referral Program, Plerdy does not require the Client to provide additional Personal Data.

3.11 The Client has the right to get acquainted with the Referral and Affiliate Program, Guest Post by using the link to the Terms of Use.

3.12 The Platform has the right to use Personal Data for the following purposes:

3.12.1 to provide Tools;

3.12.2 during registration and authorization;

3.12.3 to ensure the security of the Site;

3.12.4 to administer the Site and conduct internal operations, including troubleshooting, data analysis, testing and completin surveys;

3.12.5 to inform the Client about new types of Tools, change in the value of Tools, news, etc.;

3.12.6 to improve the navigation of the Site, based on your preferences;

3.12.7 to implement the terms of the Referral and Affiliate Program;

3.12.8 to communicate with the Client;

3.12.9 to send information in accordance with the terms of the subscription;

3.12.10 to accommodate the Guest Post;

3.12.11 to respond to requests from law enforcement agencies;

3.12.12 to initiate responses to lawsuits, investigate or resolve disputes with you.

3.13 Suppose the Client provides Personal Data of the Platform User, including receiving the User's Personal Data via the Pop-up form. In that case, the Client is obliged to inform the User that his Personal Data may be processed by the Platform and obtain the User's consent to processing his Personal Data.

3.14 During the provision of access to the video session, Plerdy has the right to collect data regarding the behavior of the Client, but only data that is publicly available or not directly related to Personal Data, that is, it is general data, such as search data, etc. Upon receipt of such data, the provisions of this Privacy Policy apply. The Client has the right to refuse the processing and storage of such data by Plerdy by writing a request to Plerdy support at: [email protected]

4. PERSONAL DATA TRANSFER

4.1 The Platform has the right to transfer Personal Data to Third Parties for the implementation and provision of the Tools and/or protection of its legal interests:

4.2 Contractors and employees. The Platform may transfer Personal Data to other entities with which it will cooperate, including legal and tax consultants and entities that provide accounting, marketing and IT services.

4.3 Courts, law enforcement, and government agencies. The Platform has the right to transfer Personal Data in the event of fulfilling any legal obligations, including in connection with a court ruling.

4.4 Third Party. The Platform has the right to disclose or transfer the Client's Personal Data during the following transactions: acquisition or merger, financing, corporate reorganization, joint venture, including the sale of assets or in the event of bankruptcy.

5. CLIENT CONSENT

5.1 The following actions are considered to be the Agreement with the terms of processing of Personal Data specified in the Privacy Policy and the terms of providing the Tools:

5.1.1 registration on the Site;

5.1.2 integration of Plerdy Tools on your website;

5.1.3 participation in the Referral and/or Affiliate Program.

5.2 The Platform reserves the right to obtain the Client's Consent via the Pop-up form. The Pop-up form may contain a Consent form in the Checkbox view.

6. PERSONAL DATA STORAGE

6.1 The Platform uses all necessary security and protection measures for Personal Data to ensure its confidentiality and prevent loss or misrepresentation.

6.2 The Platform protects and stores Personal Data from:

6.2.1 losses;

6.2.2 illegal use, transfer, disclosure, alteration, removal and/or destruction.

6.3 The Platform may delete a Data Subject’s Personal Data upon receipt of a request from the Data Subject and upon the termination of the relationship. By deleting Personal Data, we mean deleting all Personal Data from servers and/or written media.

6.4 Plerdy has the right to retain Personal Data of Data Subjects for 5 (five) years after the termination of the relationship in the following cases:

6.4.1 for statistical accounting;

6.4.2 if the current legislation requires their storage;

6.4.3 if they are necessary for doing business.

6.5 The Platform does not store the Client's Personal Data in the event of a request to delete Personal Data on his behalf in accordance with the right to delete, as provided in Article 17 of the "Right to Erase" GDPR.

6.6 A Plerdy employee performs the process of deleting Personal Data. The Client has the right to delete the Account independently, using the appropriate section in his Account. In case of deleting the Account, the Client's Personal Data will be deleted by the employee of the Platform.

6.7 Plerdy has the right not to delete Personal Data in the event of a reorganization of the company, the merger of Plerdy with another company, or any other changes in the structure of Plerdy, and in the event of a change of server.

6.8 The Platform has the right to delete Personal Data if the Client does not use the Tools within 6 (six) months.

7. BASIS FOR PROCESSING PERSONAL DATA

7.1 The Platform collects and processes Personal Data by the specified legislation and jurisdiction of the Data Subject.

7.2 The Platform processes Personal Data based on the following legal grounds:

7.2.1 Client's Consent;

7.2.2 integration of Plerdy Tools;

7.2.3 to comply with the provisions of applicable law, for the proper level of our business, the conclusion, and execution of corporate transactions (sale of shares/stocks, mergers, acquisitions), to fulfill your obligations to you and/or the Third Party.

7.3 In cases where the basis for the processing of Personal Data is your Consent, you have the right to revoke it at any time. In the event of withdrawal of your Consent, the Platform has the right to terminate the provision of the Tools and terminate all relations with you. If the Consent is revoked, your Personal Data will be permanently deleted.

7.4 The Platform undertakes to stop processing Personal Data within 10 (ten) working days from the date of receipt of the withdrawal of the agreement.

8. JURISDICTION OF THE EUROPEAN UNION AND THE EUROPEAN ECONOMIC ZONE

8.1 The terms of this section apply to residents of the European Union and the European Economic Area. By the terms of this clause, the Data Subject has the following rights:

8.2.1 Right of access. The Privacy Policy lists the Personal Data of the Data Subject. The Data Subject may contact us directly to request access to the Personal Data we hold about them, as well as to any information in accordance with Article 15 of the General Data Protection Regulations.

8.2.2 Right to erase. The Data Subject has the right to delete Personal Data about himself, in accordance with Article 17 of the General Data Protection Regulations. Personal Data, in this case, will be deleted forever.

8.2.3 Right to rectification. The Data Subject has access to Personal Data, which must be updated, corrected, supplemented at any time. The Data Subject may also contact the Client support of the Platform to access his Personal Data to correct, change, or delete it according to Article 16 of the General Data Protection Regulations.

8.2.4 Right to data portability. We may send the Personal Data Subject's Personal Data to third parties at the request of the Data Subject, in accordance with Article 20 of the General Data Protection Regulations.

8.2.5 Right to object. The Data Subject has the right at any time to object to the processing of their Personal Data in accordance with Article 21 of the General Data Protection Regulations.

8.2 Suppose the Data Subject believes that his/her rights have been violated during the processing of Personal Data or that he/she is concerned about the methods of processing Personal Data, he/she has the right to file a complaint to the Data Protection Supervisor.

8.3 Depending on the circumstances, the Data Subject complains about the supervisory authority at his registration, stay, employment, or with the country's supervisory authority in which he is resident.

8.4 Use the list provided to get acquainted with the supervisory authorities.

8.5 The Data Subject must provide sufficient information to confirm his identity, whose Personal Data are processed by the Platform. If the Data Subject cannot confirm his/her identity, the Platform has the right not to fulfill such a request until the confirmation of such identity.

8.6 The Data Subject's request must contain accurate information on the requirements it places on the Platform. If the request does not specify the exact requirements, the Platform has the right to refuse to fulfill the request.

8.7 We will not be able to respond to your request or provide you with Personal Data unless we are able to verify your identity or authority and confirm that the Personal Data relates to you. In case of receiving a request with inaccurate information and/or in case of impossibility to verify the identity of the Data Subject, the Platform has the right not to process the received request and apply to the Data Subject for clarifications. If a request for clarification is received, the Data Subject is obliged to submit a new corrected request or submit a new request.

8.8 The Platform must respond to the request or fulfill the conditions outlined in the request within 21 (twenty-one) business days from the date of receipt.

9. US JURISDICTION

9.1 The terms of this section apply to U.S. residents contained in the Privacy Policy and apply to specific requirements under the California Consumer Privacy Act 2018 (Cal. Civ. §§ 1789.100-1798.199) and the California Consumer Confidentiality Regulations passed by the Attorney General. (“CCPA”).

9.2 The Platform collects the Personal Data of US Resident Data Subjects under the terms of Section 3 of this Privacy Policy.

9.3 The Platform has the right to disclose Personal Data to a Third Party for business purposes (as defined in the CCPA). When the Platform discloses Personal Data for commercial purposes, we enter into an agreement that describes the purpose and requires that both parties maintain the confidentiality of Personal Data and not use it for any purpose other than to perform the contract.

9.4 The Platform does not support "Do Not Track" ("DNT"), according to the California Internet Security Act (CalOPPA). Do not track is a setting that you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable the Do Not Track feature by visiting your web browser's settings page.

9.5 Rights granted to US residents:

9.5.1 Right of access. The Privacy Policy lists the Personal Data of the Data Subject. The Data Subject may contact us directly to request access to the Personal Data we hold about him.

9.5.2 Right to erase. The Data Subject has the right to delete Personal Data about himself, in which case it will be deleted forever.

9.5.3 Right to rectification. The Data Subject has access to Personal Data, which must be updated, corrected, supplemented at any time.

9.5.4 Right to data portability. We may send Personal Data to third parties and at the request of the Data Subject.

9.5.5 Right to object. The Data Subject has the right to object to the processing of Personal Data at any time.

9.5.6 Right to withdraw the Consent. The User has the right to withdraw his Consent to the processing of Personal Data at any time, in which case the Platform has the right to stop providing the Tools.

9.6 The User may appoint an authorized agent to submit a request under the CCPA on your behalf if:

9.6.1 An authorized agent - is a natural or legal person registered with the Secretary of State of California;

9.6.2 You sign a written statement that you allow the authorized agent to act on your behalf;

9.6.3 If you are using an authorized agent to request the exercise of your right to information or your right to remove, please send a certified copy of your written statement that allows the authorized agent to act on your behalf using the contact information below.

9.7 The Platform must respond to the request or fulfill the conditions outlined in the request within 21 (twenty-one) business days from the date of receipt.

9.8 Data recording. Plerdy stores the Client's Personal Data during the video session. But the Client has the right to independently add a "tag" input attribute, for example, plerdy_alllloww. After that, Plerdy will start recording and displaying Personal Data for the Client in the field. But Plerdy has the right to block the following Personal Data to provide access to the video session: e-mail and any consecutive in order to prevent the receipt of bank card details or contact phone number and their subsequent processing.

10. JURISDICTION OF THE RUSSIAN FEDERATION

10.1 The terms of this section apply to residents of the Russian Federation contained in the Privacy Policy and relate to specific requirements in accordance with the Constitution of the Russian Federation, Federal Law № 152-FZ "On Personal Data", bylaws and features of personal data processing of federal laws of the Russian Federation and methodological documents of the FSTEC of Russia and the FSB of Russia.

10.2 Plerdy collects Personal Data of residents of the Russian Federation under the conditions provided by Section 3 of this Privacy Policy.

10.3 As Plerdy processes Personal Data, by the legislation of the Russian Federation, Plerdy is an operator for the processing of Personal Data. To settle the relationship with the Data Subject and grant it the rights provided by the legislation of the Russian Federation, Plerdy is guided by the provisions described in this section.

10.4 The Plerdy processes Personal Data only if it has at least one of the following conditions:

10.4.1 by Consent;

10.4.2 to achieve the objectives provided by law, for the implementation and performance of the functions of the operator of the Russian Federation, the functions, powers, and responsibilities;

10.4.3 to perform the contract, the party to which is either the beneficiary or the guarantor is the Data Subject, as well as to conclude the contract on the initiative of the Data Subject;

10.4.4 to exercise the rights and legitimate interests of the Platform or Third Parties or to achieve socially significant goals, provided that the rights and freedoms of the Data Subject are not violated;

10.4.5 an unlimited number of persons to whom the Data Subject is provided or at its request;

10.4.6 Personal Data processing is subject to publication or mandatory disclosure in accordance with federal law.

10.5 The Data Subject whose Personal Data is processed has the right to receive the following information from the Plerdy:

10.5.1 confirmation of the fact of Personal Data processing;

10.5.2 legal grounds and purpose of Personal Data processing;

10.5.3 name and location of the Plerdy;

10.5.4 information about persons who have access to Personal Data or to whom Personal Data may be disclosed based on an agreement with the Plerdy or based on federal law;

10.5.5 a list of processed Personal Data relating to the Data Subject from which the request was received and the source of their receipt, unless otherwise provided by federal law;

10.5.6 information on the terms of processing Personal Data, including the terms of their storage;

10.5.7 information on the procedure for exercising the rights provided by the Federal Law "On Personal Data" № 152-FZ;

10.5.8 information on the ongoing or anticipated cross-border transfer of Personal Data;

10.5.9 name and address of the person who processes Personal Data on behalf of the Platform;

10.5.10 other information provided by the Federal Law "On Personal Data" № 152-FZ or other federal laws;

10.5.11 require clarification of their Personal Data, their blocking or destruction if the Personal Data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of the processing;

10.5.12 withdraw your Consent to the processing of Personal Data;

10.5.13 demand the elimination of illegal actions of the Platform in relation to his Personal Data;

10.5.14 to appeal against the actions or inaction of the Platform in the Federal Service for Supervision in the Field of Communications, Information Technologies and Mass Communications (Roskomnadzor) or court if the Data Subject believes that the Platform processes its Personal Data in violation of Federal law № 152-FZ "On personal data" or otherwise violates his rights and freedoms;

10.5.15 to protect their rights and legitimate interests.

10.6 When processing Personal Data, we may be further guided by the provisions of European Union law and grant the Data Subject additional rights under European Union law.

10.7 Under the legislation of the Russian Federation, the Plerdy may request confirmation of its residence from the Data Subject.

10.8 To confirm its rights, the Data Subject must send a request to the Plerdy. The request has the following information: identifying data, indicating the rights, clearly stated requirements, and contact details.

10.9 The request of the Data Subject must comply with the requirements set out in paragraph 10.10 and must be sent in writing. If the request does not specify the exact requirements and/or it is not sent in writing, the Plerdy has the right to refuse the request.

10.10 In case of non-receipt of confirmation of the data subject's residence or receipt of a vague request, the Plerdy has the right not to process the Personal Data and to refuse the Data Subject to execute it. In this case, the Data Subject shall not be entitled to require compliance with the requirements specified in the request.

10.11 Plerdy is not obligated to execute the request if it is not submitted on behalf of the Data Subject. On his or her behalf, the Data Subject may not instruct another person to make a request to Plerdy for the information specified in paragraph 10.5.

10.12 Plerdy reserves the right to suspend the processing of Personal Data in the following cases:

10.12.1 if the Client has not confirmed his/her residence;

10.12.2 if Plerdy has reason to believe that the Client has provided inaccurate Personal Data;

10.12.3 if the Client has not provided his Personal Data and/or provided the User's Personal Data without the relevant permission from the User.

10.13 In the event of a temporary suspension of the processing of Personal Data, Plerdy will notify the Client of such suspension. If the Client does not respond to such notice within 14 (fourteen) calendar days, Plerdy has the right to suspend the provision of Tools to the Client and delete his Personal Data.

10.14 If the Plerdy refuses the Data Subject to consider its request, it shall notify the Data Subject of such refusal within 14 (fourteen) business days.

10.15 Plerdy must respond to the request or fulfill the conditions outlined in the request within 21 (twenty-one) business days from the date of receipt.

10.16 Plerdy has the right not to respond to a request from the Data Subject in the event of force majeure that interferes with the operation of the server and the Internet and / or the operation of Plerdy.

11. JURISDICTION OF UKRAINE

11.1 The conditions of this section apply 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."

11.2 The Platform collects Personal Data of Data Subjects of residents of Ukraine under the conditions provided by Section 3 of this Privacy Policy.

11.3 Rights of the Data Subject in connection with the transfer and Personal Data processing:

11.3.1 know about the sources of collection, location of Personal Data, the purpose of their processing and location;

11.3.2 receive information on the conditions for granting access to Personal Data, in particular, information on Third Parties to whom they are transferred;

11.3.3 receive, no later than thirty calendar days from the date of receipt of the request, except as provided by law, an answer as to whether the Personal Data is processed;

11.3.4 send a reasoned request to deny the processing of Personal Data;

11.3.5 send a reasoned request to change or delete Personal Data;

11.3.6 to protect Personal Data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, non-provision, or untimely provision, as well as to protect against the provision of information that is inaccurate or discredits the honor, dignity, and business reputation of the Data Subject;

11.3.7 apply to the court with complaints about the Personal Data processing;

11.3.8 use legal remedies in case of violation of the legislation on Personal Data protection;

11.3.9 make reservations regarding the restriction of the right to the processing of Personal Data during the Consent;

11.3.10 withdraw Consent to the processing of Personal Data;

11.3.11 know the mechanism of automatic Personal Data processing;

11.3.12 to protect against an automated decision that has legal consequences for him.

11.4 To confirm its rights, the Data Subject must send a request to the Platform. The request has the following information: identifying data subject data, indicating the rights that, in the opinion of the data subject, have been violated, clearly stated requirements, and contact details.

11.5 The request of the Data Subject must comply with the requirements set out in paragraph 11.4 and must be sent in writing. If the request does not specify the exact requirements and/or it is not sent in writing, the Platform has the right to refuse the request.

11.6 If the confirmation of the data subject's residence is not received or a vague request is received, the Platform has the right not to process the Personal Data.

11.7 If the Platform refuses the Data Subject to consider its request, it shall notify the Data Subject of such refusal within 14 (fourteen) business days.

11.8 The Platform must respond to the request or fulfill the conditions outlined in the request within 21 (twenty-one) business days from the date of receipt.

12. JURISDICTION OF THE FEDERAL REPUBLIC OF BRAZIL

12.1 The conditions of this section apply to residents of the Federative Republic of Brazil contained in the Privacy Policy and relating to specific requirements, in accordance with the provisions of the legislation of the Federative Republic of Brazil, in particular the General Personal Data Protection Act 13709/2018 (LGDP).

12.2 The Platform collects the Personal Data of Resident Data Entities of the Federative Republic of Brazil under Section 3 of this Privacy Policy.

12.3 According to Art. 18 “Personal Data Subject's Rights in Relation to the Controller” of the General Law on Personal Data Protection 13709/2018, the Data Subject has the right to:

12.3.1 confirmation of personal data processing;

12.3.2 access to personal data;

12.3.3 correction of incomplete, inaccurate, or outdated Personal Data;

12.3.4 anonymization, blocking or deletion of unnecessary, excessive or processed Personal Data in violation of the provisions of this Law;

12.3.5 transfer of Personal Data to another provider of services or products, upon explicit request, in accordance with the regulations of the national authority, which is a commercial and industrial secret;

12.3.6 deletion of Personal Data, which are processed with the consent of the Data Subject, except as provided in Art. 16 of this Law;

12.3.7 obtaining information about public and private persons with whom the Controller shared Personal Data;

12.3.8 getting information on the possibility of non-consent and the consequences of refusal;

12.3.9 withdrawal of the Consent, in accordance with paragraph 5 of Art. 8 of this Law.

12.4 The rights provided for in this Article shall be exercised at the direct request of the Data Subject or the legal representative.

12.5 The Platform must respond to the request or fulfill the conditions outlined in the request within 21 (twenty-one) business days from the date of receipt.

13. JURISDICTIONS OF OTHER COUNTRIES

13.1 The Platform makes every effort to legally process Personal Data under international standards for Personal Data processing.

13.2 This Privacy Policy sets out the main legislation regarding the processing of Personal Data.

13.3 Unfortunately, we do not have the opportunity to specify the legislation on the Personal Data processing of each jurisdiction in the world.

13.4 The conditions of this Privacy Policy describe the fundamental rights of the Data Subject provided for in the basic provisions of the leading legal acts governing the processing of Personal Data.

13.5 If you believe that the provisions of this Privacy Policy violate and/or in any way limit your rights regarding the processing of Personal Data, please get in touch with us by e-mail: [email protected], and we will make every effort to resolve this in a matter of reasonable time.

14. RESPONSIBILITY

14.1 The Platform notifies the Data Subject that its Personal Data may be used to provide the Tools, and in case of disagreement, the Data Subject must leave the Site and not use the Platform Tools.

14.2 The Platform has the right to collect the Personal Data of the Data Subject to obtain statistical data.

14.3 The Platform is not responsible for:

14.3.1 loss of Personal Data in the event of a hacker attack, hacking of the Site software, illegal actions of third parties, illegal actions of the Client and actions that violate the terms of the Privacy Policy;

14.3.2 provision by the Client of inaccurate information and Personal Data;

14.3.3 placement by the Client on the pages of the Blog of content that contains false information and violates the intellectual property rights of third parties; which violates dignity, religious beliefs, sexual orientation, and/or contains signs of racial discrimination and/or violation of other third party rights.

14.4 We do not record videos, take screenshots or view the information that Users provide to the Platform, except for viewing the video session, as requested by the Client.

14.5 We store the collected information, but only the Client who owns the Account can access it. Plerdy does not use the data collected to distribute newsletters without your Consent.

14.6 Unfortunately, the transmission of information via the Internet may not be completely secure. Although we make every effort to protect your Personal Data, we cannot guarantee the secure process of transferring your Personal Data to our Site. In this regard, you are solely responsible for possible failures in sharing your Personal Data with the Site. Upon receipt of your Personal Data, we undertake the necessary technical and security measures to prevent unauthorized access to your Personal Data.

15. COOKIE

15.1 Plerdy purposefully does not use Cookies, but when you use the Site, we may use cookies to improve the Site's functions. For example, Cookies allow Plerdy to store information for Client authorization (but not a password).

15.2 You can prevent Cookies from being viewed in incognito mode, and you can block or delete Cookies in your browser settings. However, we would like to warn you that this may adversely affect your use of Plerdy Tools.

15.3 The Platform can use the following web analytics services:

15.3.1 Facebook;

15.3.2 Google Analytics;

15.3.3 Linkedin.

16. ADULT POLICY

16.1 The Platform Tools are intended for Clients for adults. The Platform does not process the Personal Data of minors.

16.2 If you are a minor, you may not use Plerdy Tools.

16.3 Plerdy has the right to delete the Personal Data of a minor, without warning and any consequences for the Platform, and to terminate the provision of such person to the Tools.

16.4 If you have information about the use of the Tools by a minor, please contact Platform support by sending an email to: [email protected].

17. CHANGES TO THE PRIVACY POLICY

17.1 The Platform has the right to change the Privacy Policy provisions to ensure the preservation of Personal Data and in case of changes in the legislation governing the processing of Personal Data.

17.2 The Platform notifies Clients of changes to the Privacy Policy by posting news on the Site. Plerdy updates the date of changes to the current version of the Privacy Policy in the "Last Update" line.

17.3 The Client is obliged to read the new terms of the Privacy Policy, and the Platform is not responsible if the Client has not read the new terms of the Privacy Policy.

17.4 Electronic or otherwise retained copies of the Privacy Policy are considered genuine, complete, valid, and enforceable versions of this Privacy Policy in effect when the Client visits the Site. If the Client uses the Tools after updating the Privacy Policy, He agrees with the new rules of Personal Data processing.

18. CONTACTS

18.1 The Client has the right to contact the support service of the Platform at: [email protected] to ensure his rights, by the terms of this Privacy Policy, or in case of violation of his rights, or to leave a response or ask questions.

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