Kartka Privacy Policy

Effective as of Jan 1, 2025.

This Privacy Policy describes the ways we collect, store, use and manage the information you provide to us or we collect in connection with your use of Kartka website accessible at https://kartka.top and our other websites on which this Policy appears (the ‘Site’), and your use of all services we provide (the ‘Services’).

When we refer to ‘we’ (or ‘our’ or ‘us’) that means UKRAINIAN BUSINESS INTELLIGENCE AGENCY, LLC, a Ukrainian company whose company registered number is 40979910 and registered address is at 4 Kv. 4 vul. Moskovska Kherson, 73000 Ukraine.

We have updated Our Privacy Policy with the aim to reflect the changes and comply with requirements of European Union General Data Protection Regulation which enters into force on the 25th of May 2018.

When talking about ‘Personal Data’ we mean identifiable information about you, like your email address, username, first and last name and so on. If you can’t be identified (for example, when Personal Data has been aggregated and anonymized), then this Policy does not apply.

BY SUBMITTING YOUR INFORMATION TO US AND USING THE WEBSITE AND/OR SERVICES YOU AGREE TO THIS PRIVACY POLICY and the processing of your Personal Data in the manner provided in this Policy.

BY REGISTERING ON THE SITE AND/OR BY USING THE SITE, YOU AGREE TO THESE TERMS OF USE AND OUR PRIVACY POLICY, AND YOU AGREE TO TRANSACT WITH US ELECTRONICALLY. IF YOU DO NOT AGREE, PLEASE DO NOT USE THE SITE.

1. What Data We Collect and How We Do That

When you visit our Site or use our Services we collect and process your Personal Data. The ways we collect it can be broadly categorized into the following:

Information you provide to us directly
When you visit or use some parts of our Site we might ask you to provide Personal Data to us. For example, we ask for your contact information upon registration or when you contact us with questions or request support, or certain documents during verification check.

Information we collect automatically
We collect some information about you automatically when you visit our Site or use our Services, like your IP address, the type of device you use, ID or serial numbers of your device, browser type, version and language, type and version of your operating system, and the number and frequency of visitors to the Site. This information is useful for us as it helps us get a better understanding of how you are using our Site and Services so that we can continue to provide the best experience possible.

Some of this information is collected using cookies, similar tracking technologies and third-party tools like Google Analytics.

If you want to find out more about the types of cookies we use, please, see Section 9 ‘Cookies’ below.

We also collect details of the transactions you carry out with us and your account activity.

Information we get from third parties
Sometimes we might collect Personal Data about you from other sources, such as publicly available materials or trusted third parties like our payment providers. We use this information to supplement the Personal Data we hold about you, in order to better inform, personalize and improve our Services, and to validate the Personal Data you provide.

If you use your Google, Facebook, Apple or other third-party log-in service (“Third-Party Service”) account information to sign up/in to the Site, we will collect and store your Third-Party Service user ID. If you connect your account with us with your Third-Party Service account, we ask for your permission to collect certain information from your Third-Party Service account. We use your information from such Third-Party Service account only in accordance with your privacy settings you have set up with that Third-Party Service.

2. Legal Grounds to Process Personal Data

Where we collect Personal Data, we will only process it when we have the legal basis for the processing set out in applicable data protection laws. Such legal bases are:

The performance of a contract
We may process your Personal Data where we need to take steps at your request prior to entering into a contract, in particular, during your enrollment in the Services, or where it is necessary for the performance of a contract. For example, when your application is accepted you enter into agreement with us, or when we take steps related to a contract, in particular, facilitation of transactions that take place when you use the Site and/or Services.

A legal obligation
Various laws and regulations impose certain obligations on us. To comply with them we have to process your Personal Data, for example, to comply with advertisement legislation and responsible gaming regulations.

The legitimate interests
Your Personal Data may be processed when we, other companies in our group of companies or third parties have a business or commercial reason to process your Personal Data.

Your consent
In certain limited cases we process your Personal Data based on your consent, for example, when it is required for direct marketing purposes.

3. How We Use Personal Data

Our processing of your Personal Data is necessary for us to provide you with the Services you have requested. If we do not process your Personal Data, we may be unable to provide you with all features of the Services, and some functions and features on our Site may not be available to you.

We use your Personal Data for a number of purposes, which may include the following:

Use of your Personal Data	Legal basis
To operate our Site, ensure our Site and Services work as intended and deliver services you have requested	Performance of a contract Legitimate interest
To set up and operate your account; to determine if you are qualified to use the Services Performance of a contract	Legitimate interest
To perform legal duties, responsibilities, and obligations; and to comply with any laws and regulations that apply to us and prevent illegal activities	Legal obligation
To support you, including assisting with the resolution of technical or payment issues or other issues relating to the Site or Services	Performance of a contract
To enhance our Site and Services, test and develop new features and carry out technical analysis of our Site and Services so that we can optimize your user experience and provide you with more efficient tools	Legitimate interest
To prevent, detect and report crime, protect you, other users and us, for example, by ensuring network and information security, mitigating security risks, detecting and preventing any fraudulent or malicious activity, and make sure that everyone is using our Site and Services fairly and in accordance with our Terms of Use	Legal obligation Legitimate interest Performance of a contract
To analyze and aggregate data, to prepare statistics, in particular, to produce aggregated and anonymized analytics and reports, which we may use internally or share publicly or with third parties	Legitimate interest
To facilitate, manage and confirm financial transactions	Performance of a contract Legitimate interest
To exercise our rights set out in our Terms of Use or other agreements with you	Performance of a contract
To disclose information to companies in our group of companies following a restructure or for internal administrative purposes	Legitimate interest
To manage our relationship and communicate with you. This may include: - operational communications, like changes to our Site and Services, information about new features, security updates, or assistance with using our Site and Services, - providing you with the information you have requested from us or information we are required to send to you, and - marketing communications	Performance of a contract Legitimate interest Your consent

4. How We Can Share Your Personal Data

There will be times when we need to share your Personal Data with third parties. We will disclose your Personal Data to:

Other companies in our group of companies;
Third-party service providers and partners who assist us in the provision of Site and Services which you have requested, for example, to those who support delivery of or provide functionality on Site or for Services, or market or promote our Site and Services;
Regulators, law enforcement agencies, government bodies, courts, fraud prevention agencies, licensing bodies or other third parties, where we think it is necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights (where possible and appropriate, we will notify you of this type of disclosure);
Affiliates and other persons that introduce you to us;
Identity verification agencies;
An actual or potential buyer (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of our business; and/or Other persons where we have your consent.

5. International Data Transfers

When we process and share data, it may be transferred to, and processed in, countries other than your country. These countries may have laws different to what you are used to. Where Personal Data are processed in another country, we put safeguards in place to ensure your Personal Data remains protected.

For individuals in the European Economic Area (EEA), this means that your data may be transferred outside of the EEA. Where your Personal Data is transferred outside the EEA, it will be transferred to countries where we have compliant transfer mechanisms in place to protect your Personal Data, in particular, by implementing the European Commission’s Standard Contractual Clauses to the contracts with the entities the data is transferred to.

6. Security

We are committed to protecting your Personal Data and have appropriate technical and organizational measures in place, including:

Data encryption. We encrypt all data that goes between you and us using industry-standard TLS (Transport Layer Security), protecting your personal and financial data. Your data is also encrypted when it is stored on our servers, and encrypted when we transfer it between data centres for backup and replication.
Limited access. We restrict access to personal information to our employees, contractors, and agents who need that information in order to process it.
Network protection. Multiple layers of security controls protect access to and within our environment, including firewalls, intrusion protection systems and network segregation. Our security services are configured, monitored and maintained according to industry best practice. We partner with industry-leading security vendors to leverage their expertise and global threat intelligence to protect our systems.
Secure data centres. Our servers are located within enterprise-grade hosting facilities that employ robust physical security controls to prevent physical access to the servers they house. These controls include 24/7/365 monitoring and surveillance, on-site security staff and regular ongoing security audits. We maintain geographically separated data replicas to minimize the risk of data loss or outages.
Security monitoring. Our security team continuously monitors security systems, event logs, notifications and alerts from all systems to identify and manage threats.

7. Data Retention

Some data you can delete whenever you like, some data is deleted automatically, and some data we retain for longer periods of time when necessary. When the data is being deleted, we make sure that your data is safely and completely removed from our servers or retained only in anonymized form.

Information retained until you remove it We offer a range of services that allow you to correct or delete data associated with or stored in your account. For example, you can: Edit information about yourself (except for your username), or Delete your account entirely by contacting our support team. We will keep this data in your account until it is not closed, and for as such period as specified in the applicable laws to allow us to meet our regulatory and legal obligations and defend ourselves against any claims following the closure of your account (when applicable) or your last contact with us.

Information retained for extended time periods for limited purposes Sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. Reasons we might retain some data for longer periods of time include:

To protect you, other persons, and us from fraud, abuse, illegal activity and unauthorized access, for example, when suspect someone is committing fraud, is engaged in match-fixing or launders money. To comply with tax, anti-money laundering and other financial regulations, to carry out accounting or facilitate dispute resolution, for example, when we are party to a financial transaction, including when we make payments to you. To meet any comply with applicable law, regulation, legal process or enforceable governmental request, or when we are required to enforce our Terms of Use, including investigation of potential violations. To ensure that the Site and/or Services is available to you and other users. If you have directly communicated with us, for example, through a customer support channel or providing feedback or a bug report.

8. Your Rights

You have the following rights with respect to your Personal Data that we process:

Right to access. You have the right to access (and obtain a copy of, if required) your Personal Data.
Right to rectification. You have the right to update your Personal Data or to correct any inaccuracies.
Right to erasure. You may have the right to request that we delete your Personal Data in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
Right to restriction of processing. You may have the right to request to restrict the use of your Personal Data in certain circumstances, such as when you have objected to our use of your Personal Data but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability. You have the right to transfer your Personal Data to a third party in a structured, commonly used and machine-readable format, in circumstances where the Personal Data is processed with your consent or by automated means.
Right to object. You may have the right to object to the use of your Personal Data in certain circumstances, such as the use of your Personal Data for direct marketing.
Right to complain. If you are not happy with how we are processing your Personal Data, please let us know by sending an email to support@kartka.top. We will review and investigate your complaint, and try to get back to you within a reasonable time frame. You have the right to complain to your local data protection authority. This right may not be available to you if there is no authority dealing with data protection in your country.

You can exercise your rights at any time by making adjustments in your account or by sending an email to support@kartka.top.

We may require evidence of and be satisfied as to your identity before we take any requested action.

9. Cookies

What is a cookie?
A cookie is a small text file that gets downloaded onto your device when you visit our Site. They generally contain two bits of information: a site name and a unique user ID. Once the cookie is on your device, our Site "knows" that you have been there before and can then use that knowledge to tailor the experience that you have.

Why do we use cookies?
The Site uses the technical information contained in the cookies to understand how you interact with the Site and the Services and to measure their effectiveness.

Cookies help to improve the security of the Site, as we can determine inconsistencies between devices used, remember the settings you apply for your use of the Site and as such personalise your experience, and continually improve the way in which the Site operates for you.

Cookies also allow us to make our marketing more relevant for you as we can better understand which of our content and/or services you are interested in.

Different types of cookies
The different types of cookies that we may use on our Websites fall into the categories described below. These descriptions can help you determine if and how you would like to interact with the Site:

Required cookies. Required cookies enable basic site functionality and follow your progress through the Site. These essential cookies have to be enabled, in order for you to browse the Site and move between pages.

Anonymous visitor statistics cookies. We use Google Analytics to collect information about use of the Site. Google Analytics collects information such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to coming to the Site. We use the information we get from Google Analytics only to improve the Site. Google Analytics collects only the IP address assigned to you on the date you visit the Site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with your Personal Data. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to the Site by disabling cookies on your browser.

Social networking and third party function cookies. The Site interacts with social networking websites so that you can easily "like" or share our content on websites such as Facebook, YouTube, Twitter, and Instagram. You should refer to the privacy policies of these social networking websites to understand how they use your personal information.

Turning cookies off
You can change how cookies are stored on your device in your internet browser for your device. You can also learn more about cookies by visiting the third party website www.allaboutcookies.org which includes additional information on cookies and how to block cookies using different types of browser. For more information about these controls, visit your browser or device's help material.

Certain parts of the Site may not work properly if you have disabled browser cookie use.

10. Modifications

We reserve the right, at our sole discretion to put into effect, modify or revise this Policy at any time by posting the Policy or revised Policy on the Site. The Policy or any changes will become effective upon posting of the revised Policy. If we make any material changes to the Policy we will use reasonable efforts to inform you by email or by posting a notice on the Site.