PRIVACY POLICY
This Privacy Policy is developed and used by TTN Eesti OU ("we" / "Organizer") to regulate the collection, processing, use, transfer and other use of Personal Data of individuals participating in the Loyalty Program ("You" / "Participant"), the terms of which are regulated by the Loyalty Program Rules, available at the following link: https://kosmostechno.com/en/topic/rules (hereinafter "Loyalty Program Rules"/"Rules").
The Organizer collects and processes Personal Data of the Loyalty Program Participants for the purposes, which are somehow related to the implementation of the Loyalty Program. All details of the processing of Personal Data are determined by this Privacy Policy and the Loyalty Program Rules.
DEFINITIONS
Organizer - TTN Eesti OU, a company registered according to the legislation of Estonia (located at: Estonia, Harju Maakond, Tallinn, F. R. Kreutzwaldі 4-7 office 405, 10120).
Bank - Technobank open joint stock company, located at: 220004, Minsk, 44 Kropotkina str., financial institution-issuer of Visa bank cards, which participate in the Program.
Website - the Loyalty Program platform, consisting of a set of logically linked hypertext information, designed in the form of separate pages and available on the Internet at http://kosmostechno.com, which contains the Participant's Accounts and where the Participant's requests to exchange Points for Rewards are processed in accordance with the Rules.
KOSMOS Loyalty program ("Loyalty Program" or "Program") is a unique system designed to allow Participants to accumulate and exchange Points for Rewards on the Website.
Partner - A company that allows Loyalty Program Participants to exchange Points for Rewards in accordance with the Rules. Participants can see the list of Partners on the Program Website. The Organizer reserves the right to change the list of Partners without prior notice to Participants.
Participant / the Loyalty Program Participant- an individual, a citizen of the Republic of Belarus, who is aged 18 at the time of registration in the Program and who is the Cardholder and has provided Bank with his personal passport number.
Card - a bank payment Visa card, issued by the Bank, which entitles the Cardholder to make non-cash payments for goods and services, receive cash and participate in the Loyalty Program in accordance with its Rules. In the context of participation in the Loyalty Program, this card is considered to be active, if the cardholder has performed transactions using it, and for which the Points are awarded in accordance with the Rules. The Cards that participate in the Program are defined in the Rules of the Loyalty Program.
Account (Cabinet) - a personal part of the interface on the Website of each Loyalty Program Participant, which is an electronic registry of information, maintained by the Organizer through its information systems, and which contains information about the credited, written off and canceled Points in accordance with the Rules of the Loyalty Program.
Data Protection Legislation - any and all data protection and privacy legislation, including, but not limited to, the legislation of the Republic of Belarus, the legislation of the country of registration of the Organizer, including the General Data Protection Regulation (EU) 2016/679 (GDPR) and any legislation and/or regulation that amends or replaces the Data Protection Legislation;
All other capitalized terms in this Privacy Policy shall be construed in accordance with the definitions contained in the Loyalty Program Rules.
GENERAL TERMS
All Personal Data, the Loyalty Program Participant transfers directly to the Organizer, shall be processed on the basis of the consent, which is provided to the Organizer by the Participant of the Loyalty Program in the process of his registration as a Participant of the Loyalty Program. The Organizer may ask the Participant of the Loyalty Program to provide only those Personal Data, which are necessary for the Organizer to implement the purposes defined in this Privacy Policy, in particular for the purposes of the Loyalty Program.
The Organizer respects the right of the Loyalty Program Participants to protect Personal Data processed by the Organizer as a result of the Loyalty Program Participants' use of this Website, as well as within the framework of the Participants' participation in the Loyalty Program, and undertakes to take all reasonable measures necessary to keep such data confidential and secure, including using generally accepted standards of technological and operational protection against possible loss, improper use, modification or destruction of Personal Data Taking into account the fact that within the information space there may be a number of specific features and threats beyond the Organizer's control, the Organizer still cannot guarantee the absolute protection of the Participants' Personal Data, but will do its best to ensure that Personal Data are protected as much as possible. Each Participant guarantees that all relevant Personal Data provided by the Participant are lawful, accurate and reliable.
PURPOSES OF PERSONAL DATA PROCESSING
For the purposes of registration and participation in the Loyalty Program, for creation of an Account in the Loyalty Program on the Website, as well as for other purposes provided for in this Privacy Policy, the Organizer may ask you to provide the following Personal Data: full name, date of birth, e-mail address, phone number, identification number of a citizen of the Republic of Belarus, your Card data, as well as other data that may be necessary for creation of an Account, in accordance with the Rules of the Loyalty Program. Your Card data may be used by the Organizer for the purpose of determining whether such Card participates in the Loyalty Program.
Once you have registered as a Participant, your Personal Data may be processed for purposes of crediting you the Points as a Participant, as well as for purposes of cancellation and write-off of Points from your Account. For such purposes, we may process your Card information, information about the outlets where you paid with your Card, and the transactions you made with your Card. Also, some of your Personal Data may be processed for the purpose of providing and enabling you to use Rewards in exchange for accumulated Points as defined in the Loyalty Program.
Taking into account the information above, you are aware that if you do not provide the Personal Data necessary to register you as a Participant and to participate in the Loyalty Program, you will not be able to register and participate in the Loyalty Program.
You are aware and have no objections concerning the fact that the contact information you have provided may be used for the purposes of sending you mandatory technical notifications related to the Loyalty Program. At the same time, your contact information may be used for the purposes of sending you news, information and / or promotional messages of the Loyalty program, but provided that you have given your own consent to such mailing when you registered for the Loyalty program. At any time during your participation in the Loyalty Program you have the right to change the settings for receiving notifications in your Account, including refusal to receive the following news, informational and / or promotional messages of the Loyalty Program.
In any case, your Personal Data will be processed only for the purposes of the Loyalty Program, for the purposes provided for in the Data Protection Laws, as well as for other purposes that may be stipulated in this Privacy Policy.
DATA FROM THIRD PARTIES
The Organizer may receive information from Visa Inc. on the transactions performed with your Card, participating in the Loyalty Program, in order to correctly count the Points credited to you within the Loyalty Program. Personal data, which the Organizer receives from third parties, is not processed for purposes not stipulated in this Privacy Policy.
When receiving Personal Data from third parties, the respective third parties guarantee that all Personal Data has been collected in accordance with legal requirements, including obtaining all appropriate consents from the owners of the Personal Data to share it with the Organizer.
Whenever necessary, the Bank, upon the consent of the Participant, may transfer some of the Participant's Personal Data to the Organizer. In particular, this refers to data subject to the bank secrecy regime, as provided by the legislation of the Republic of Belarus, to the extent determined by the need to participate in the Loyalty Program.
PERSONAL DATA OF MINOR PERSONS
The Organizer officially declares that it does not collect and does not process Personal Data of persons who are under 18 (eighteen) years old. By providing Personal Data to the Organizer, you officially confirm and guarantee that you are an adult with full legal capacity and capability. If the Organizer determines that a person who has enrolled in the Loyalty Program is a minor, the Account created by such a person and all Personal Data provided by such a person will be immediately deleted from the Loyalty Program, without prior or subsequent notice of deletion to such person.
DATA TRANSFER
Personal data, the Participant provides to the Organizer, or which may be obtained by the Organizer from third parties, may be transferred to third parties, which are defined in this Privacy Policy. Personal data may be transmitted solely for the purposes of the Loyalty Program, in which the Participant takes part.
Personal data may be disclosed to the following third parties:
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Partners. For the purpose of implementing the Loyalty Program, a Participant's Personal Data may be transferred to companies which provide Loyalty Program Participants with the opportunity to exchange Points for Rewards, which are available on the Website at the moment of exchanging Points for the corresponding Rewards, in accordance with the Loyalty Program Rules. Participants can see the list of Partners on the Program Website. The Organizer reserves the right to change the list of Partners without prior notice to Participants.
For example, one of the partners in the territory of the Republic of Belarus is the "Reut Experiences" Limited Liability Company (legal address: 223054, Minsk region, Minsk district, Ostroshitsky Gorodok, Lenina street 1-3, room 3-1-42; Contact details: Tel: +375(29)6308308, email: li@reut.by).
During the course of interaction with Partners, depending on the Reward selected by the Participant, the applicable Partner may additionally request or offer the Participant to provide Personal Information of both the Participant and other individuals accompanying the Participant or who, at the Participant's request, should use the Reward. The Promoter is not responsible for the purposes for which Partners may additionally require or suggest the Participant to provide Personal Information. However, in order to understand how Personal Data is processed by the Partners, you are strongly recommended to read the internal documents of the respective Partners regulating the processing and use of Personal Data.
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Partners Providing Travel Services. If the Participant, in order to exchange accumulated Points, wishes to use the Reward to receive Travel Services, certain Personal Data of the Participant will be transferred by the Organizer to the appropriate Partner which provides booking, ticketing and other travel services. Particularly, Personal Data provided by the Participant in order to create the Account will be transferred.
The Travel Service Partner may require or ask the Participant to provide Personal Data about the Participant or other individuals accompanying the Participant or persons the Participant wishes to receive the Reward. To understand how Personal Data is processed by a Travel Partner, we strongly recommend you to see the relevant Travel Partner's privacy policy.
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Bank. In order to implement the Loyalty Program, your Personal Data, which are processed by the Organizer within the Loyalty Program, including but not limited to data on accumulated and/or used Points, may be transferred to the Bank-issuer of your Card, which entitles the Cardholder to make cashless payments for goods and services, receive cash and participate in the Loyalty Program in accordance with the Loyalty Program Rules, and receive Points for transactions using the Card on certain conditions specified by the Bank. All Personal Data the Bank may ask you to provide or request from you in the course of communication, is collected solely by the Bank on its own behalf and for the purposes determined by the Bank itself. The Organizer has no information about the purposes for which the Bank may additionally request or offer you to provide Personal Data, and, accordingly, shall not be liable in connection with such circumstances. We strongly recommend you to see the Bank's documents, which regulate the procedure for processing and use of Personal Data.
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Legal Successor. The Organizer shall have the right to transfer any Personal Data that the Organizer holds and processes to its successor in the event when the Organizer decides to sell or transfer all or part of its business or assets. In the event of such sale or transfer, the Organizer will make every reasonable effort to ensure that the successor has documents containing the provisions corresponding to the provisions of this Privacy Policy. However, the Organizer will attempt to obtain assurances from the Successor that Personal Data transferred to it under the Loyalty Program will be used solely for the purposes set forth in this Privacy Policy.
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State Authorities. The Organizer has the right to transfer the processed Personal Data to state authorities, at their legal request, including in cases when it is necessary for taxation purposes, accounting, as well as for the purposes of maintaining and submitting tax and statistical reports.
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Contractors. The Organizer may transfer Personal Data provided by You, or collected by the Organizer during the Loyalty Program, to third parties who act and process the Personal Data on behalf of or under instructions from the Organizer. For example, these may be companies that provide technical support for the Website or that provide services for organizing mailing lists of the Loyalty Program participants. It should be noted that processing of Personal Data by such third parties is subject to this Privacy Policy and for the purposes defined solely in this Privacy Policy.
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Visa Inc. The Organizer may transfer some statistical non-identifying information to Visa Inc., in particular, the Organizer must provide Visa Inc. with Loyalty Program reports describing the number of Loyalty Program Participants as well as the number of Points accumulated and used in the Loyalty Program by all Loyalty Program Participants in total. Therefore, the Organizer can use the Personal Data to prepare reports for Visa Inc., however, it should be emphasized that the Organizer does not provide Visa Inc. with any Customers' Personal Data or any other identifying information.
In the course of processing Personal Data, the Organizer may transfer your Personal Data to third parties located in third countries. For example, it could be done for the purpose of storing your Personal Information on servers located in the United States or the European Union. We do not transfer your Personal Data to third countries without your prior consent, provided by you during the registration in the Loyalty Program.
PARTICIPANT`S RIGHTS
The Organizer respects the rights of each Loyalty Program Participant, and therefore takes all necessary measures to enable the realization of the rights of such Participants. The Participant, at any convenient time, may obtain information about his/her Personal Data processed within the framework of the Loyalty Program, in particular those stored in the Participant's cabinet, by sending a request to the Organizer in accordance with the procedure defined in this Privacy Policy.
The Participant shall have the right to send the Organizer a request to delete his Personal Data, processed by the Organizer within the Loyalty Program via message "Please delete all my data. The Organizer undertakes to delete all Personal Data of the Participant, upon request, as soon as reasonably possible. At the same time, you acknowledge that your request to delete Personal Data, submitted to the Organizer, will be considered as your voluntary will to terminate your participation in the Loyalty Program.
The Participant has the right to send the Organizer a request to suspend the processing of his/her Personal Data saying "Please suspend the processing of my Personal Data". Upon submitting the request the Participant has the right to specify the particular purposes for which the suspension is necessary, as well as the period for which he/she wishes to suspend the processing. The Organizer undertakes to suspend the processing of certain Personal Data by the Participant at his/her request, as soon as reasonably possible. At the same time, you acknowledge that the Organizer's receipt of your request to suspend the processing of Personal Data, both for certain purposes and in general, is grounds for terminating your further participation in the Loyalty Program.
If the Participant becomes aware that his/her Personal Data, which is processed within the Loyalty Program is incomplete or unreliable, the Participant shall have the right to make a motivated request to the Organizer to change his/her Personal Data. The Organizer undertakes to correct all Personal Data of the Participant on the basis of the data provided by the respective Participant. If the Participant fails to provide correct Personal Data along with the relevant request, the Organizer shall be entitled to delete such data.
In case of submitting any request, the Organizer shall make sure that the request is really submitted by the person who is registered as a Participant in the Loyalty Program. In this regard, the Organizer is entitled to require additional data from the person who submits the request in order to verify the identity of the Participant.
The data protection legislation may provide for other rights, which the Participant may exercise in the process of the Loyalty Program implementation.
STORAGE PERIOD AND DELETION OF DATA
The Personal Data provided by the Participant to the Organizer to be able to participate in the Loyalty Program, as well as the Personal Data collected by the Organizer in the course of the Loyalty Program, shall be stored during the term of the Participant's participation in the Loyalty Program. Upon termination of the Participant's enrollment in the Loyalty Program, the Organizer irrevocably deletes the Participant's Personal Data.
It should be noted that the Organizer may store some Personal Data provided by the Participant to the Organizer, when required, for the purposes of implementing the obligations imposed on the Organizer by the legislation of the country of the Organizer's registration, as well as, where necessary, the legislation of the Republic of Belarus, but no more than for 5 (five) years from the date of termination of the Participant's participation in the Loyalty Program. For example, this may apply to cases where the Organizer may use Personal Data to file, execute or defend against claims or suits, within the general limitation period, or when it is necessary for tax purposes, accounting, as well as for tax and statistical reporting purposes.
PERSONAL DATA SECURITY
Taking into account the latest developments, costs of their development and implementation, context, volume, purposes of Personal Data processing, as well as risks to the fundamental rights and freedoms of individuals, the Organizer shall take all necessary organizational and technical measures to ensure an adequate level of protection of Personal Data. The Organizer, where possible, shall apply technical means for data encryption to prevent access to data by unauthorized persons, leakage of Personal Data, unauthorized intrusion into the relevant databases or to prevent alteration and/or distortion of Personal Data, or use in any unlawful way. The Organizer shall make every effort to ensure the confidentiality, availability, security and flexibility of all information systems within which Personal Data is stored or processed. At the same time, the Organizer guarantees the possibility to restore prompt access to the availability of Personal Data in the event of any physical or technical incident. The Organizer shall maintain constant monitoring and evaluation of the level of affiliation of the adopted organizational and technical measures, in accordance with the requirements that are needed to ensure the security of personal data, in particular in the context of current threats. Among other things, the Organizer, in order to organize the maximum protection of personal data, has developed internal documents, procedures and rules that regulate the processing and security of Personal Data.
The Organizer takes the most reasonable approach to the issue of providing access to Personal Data to its employees, as well as to all other persons who in one way or another may participate in the Loyalty Program. All employees and persons involved in the processing of Personal Data shall be bound by the Organizer to observe strict confidentiality with respect to Personal Data processed under the Loyalty Program.
AUTOMATIC COLLECTION OF PERSONAL DATA
In the process of the Loyalty Program implementation, the Organizer can collect certain information by automatic means, such as cookies and system files. Personal data, which can be collected automatically, is used by the Organizer for improvement of the Website operation, implementation of the Loyalty program, as well as for timely and operative provision of information about the Loyalty program to the Participants.
Using cookies. Cookies are information in the form of text or binary data obtained from the Website on a web server, which is stored on a browser, and which is used by the Participant during the use of the Website. The use of cookies, for example, helps Organizer to determine whether and when a Participant has previously visited the Website. The information that is collected through cookies also allows the Organizer to make offers of new Rewards, for which the Participant can exchange accumulated Points.
Generally, the following types of cookies can be used:
• mandatory cookies;
• statistical cookies;
• marketing cookies.
Mandatory cookies help ensure proper and smooth operation of the Website. The use of mandatory cookies also allows Participants to take part in the Loyalty Program in a proper manner, particularly to accumulate and use the Points. The use of cookies primarily enables Participants to make appropriate use of the Website.
Cookies may also be used for statistics and analysis purposes, which allows to find out how many users visited the Website, as well as the relevant pages of the Website the users were interested in. This helps to understand and improve the Website ta the point most visited by users, as well as to understand the shortcomings of the Website that need to be corrected immediately in to ensure proper implementation of the Loyalty Program.
Marketing cookies enable to understand Participant preferences, including with respect to Rewards offered on the Website, and to select the most relevant information that may be of interest to Participants as part of the Loyalty Program and that may be forwarded to Participants.
If you do not want cookies, which may contain Personal Data about you, to be used by the Organizer, you may use the functionality of the browser that you use to visit the Website and set appropriate cookie management options. For example, you can set up and implement cookie management on the applicable browser by clicking on the following links:
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Internet Explorer |
https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies |
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Firefox |
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Google Chrome; |
http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647 |
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Opera |
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Safari |
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Safari iOS (iPhone, iPad, iPod touch) |
System file usage. While using the Website, the Organizer may also automatically collect certain log files, such as the IP address, browser type, links/pages and URLs, number of clicks and interactions with the Website, domain name, landing pages/content, revised pages/content, device identifier and its location. Under IP address, we should understand a specific identifier that certain electronic devices use to recognize and communicate with each other on the Internet. When a Participant visits the Website, the Organizer is able to collect information about the IP address of the device that the Participant uses to communicate with the Internet. In combination with other data, the information contained in the system files helps the Organizer know which pages are most attractive to our visitors. System files also help the Organizer to ensure the proper implementation of the Loyalty Program and the functioning of the Website.
LINKS TO OTHER WEB RESOURCES
The Organizer, ensuring the proper implementation of the Loyalty Program, can post links to other web resources on the Website, functioning independently of the Website. However, the web resources to which the Website is linked are not managed by the Organizer, but by third parties, and, therefore, the Organizer is not responsible for their functioning. The Organizer is not responsible for the content of these web resources, for any goods or services which may be offered through these web resources, or for any other use of them. The web resources, as stipulated above, may contain their own documents regulating their activity and the way they process Personal Data of the users of the respective web resources. We strongly recommend to read such documents before using such web resources.
PROCEDURES FOR FILING COMPLAINTS AND REQUESTS
All requests regarding the exercise of Participant's rights, as well as all complaints related to the processing of Personal Data by the Organizer within the Loyalty Program, can be sent to the following e-mail address: privacy.eesti@loyalty.services.
CHANGES
The Organizer, at its sole discretion, may, from time to time, make changes to this Privacy Policy by posting the changes on the Website. Changes to this Privacy Policy become effective on the date they are published on the Website. Each Participant agrees to independently and regularly review updates to this Privacy Policy. You agree that by continuing to participate in the Loyalty Program and use the Website, you accept all changes to this Privacy Policy. If you do not agree with the changes in this Privacy Policy, you must stop using the Website and terminate your participation in the Loyalty Program by deleting your Account.