Privacy Policy

The Privacy Policy defines ExCW’s policy regarding the processing of User Data when using the Service, and also contains information about the requirements to the protection of Users’ personal data.

POLICY VALIDITY

By using the Service (including access to the Resource, Registration, Authorization), the User agrees to the terms of ExCW Data processing described in this Privacy Policy (Policy). If the User does not agree with such terms, the use of the Service, including access to the Resource, shall be terminated.

The Policy may be amended by ExCW. The amended Policy shall be posted on the Resource. By using the Service after the Policy has been amended, the User agrees to the amended terms of Data processing.

PURPOSE AND CONDITIONS OF PROCESSING

ExCW processes Data for the purpose of providing the Service, including:

  • ensuring the functioning of the Service;
  • improving the quality and usability of the Service;
  • creation and development of existing and new products of ExCW and its partners;
  • personalization of content and other offers;
  • receiving User communications;
  • promoting the Resources, products and/or services of ExCW and its partners;
  • receiving User’s requests and providing answers to these requests;
  • conducting statistical and other studies on the use of the Service.

For the said purpose, ExCW processes the following Data:

  • surname, first name, patronymic;
  • date of birth;
  • gender;
  • telephone number;
  • e-mail address;
  • information collected through metrics programs;
  • information about the user’s device;
  • cookies, user ID, resource usage data; network address;
  • third party service account.

For the purpose stated in the Policy above, the following processing conditions apply:

ExCW does not process biometric and special categories of Users’ personal data. The personal data processed by ExCW belong to other categories of personal data.

The list of actions with Data: collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion and destruction. These actions may be carried out by both automated and unattended methods.

Period of processing and storage of Data: until the purpose of processing is achieved, until the expiration of consent or until the consent is revoked (unless there are other grounds for processing such Data), whichever comes first.

In order to provide the respective Service to the User, ExCW may, if there is a legal basis, transfer (provide, access) Data for further processing to service providers and partners specified in the relevant ExCW documents posted on the Website.

BASES OF PROCESSING

The legal bases for the processing of ExCW Data are, among others:

  • User’s consent;
  • execution and conclusion of the Terms of Use or other agreements with the User;
  • Exercising the rights and legitimate interests of ExCW or third parties, provided that the rights and freedoms of the User are not violated;
  • processing for statistical or other research purposes, provided that the Data must be anonymized;

the necessity of processing to achieve the purposes provided for by law, as well as the fulfillment of the obligations imposed on ExCW by law.

USER RIGHTS

The User has the right to:

  • Receive information regarding the processing of their Data;
  • request ExCW to clarify, block or destroy their Data if it is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing;

withdraw consent to the processing of his/her Data by sending ExCW an application.

TERMS OF USE OF COOKIES

In order to comply with the Terms of Use and for the purpose set out in the paragraphs of the Policy above, ExCW processes cookies, including for the operation of the Service; personalization of ExCW and other offers; statistical and other studies of the use of the Service. The User can view the expiration date of cookies and also prohibit their storage in the settings of their browser.

INFORMATION ABOUT THE IMPLEMENTED PROTECTION REQUIREMENTS

ExCW undertakes to ensure the confidentiality of Users’ personal data. ExCW shall ensure the security of Users’ personal data by implementing legal, organizational and technical measures.

Legal measures taken by ExCW include:

  • ExCW’s issuance of documents defining the policy regarding the processing of personal data, local acts regarding the processing of personal data, as well as local acts establishing procedures aimed at preventing and detecting violations of the law, eliminating the consequences of such violations.

OTHER

The User is responsible for the lawfulness, relevance and reliability of the User’s and other persons’ data that the User provides to ExCW.

ExCW considers communications related to the Policy, including inquiries from Users regarding the use of their Data at the e-mail address excw@eccw.com.