• Privacy policy smallsteps.in.ua

    This application collects some personal data from its users.

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  • Data owner and controller

    Terenbro, Kyiv, Ukraine

    Contact e-mail address of the owner: viktor.panasiuk@terenbro.com

  • Types of data collected

    Among the types of Personal Data collected by this Site itself or through third parties are: Cookies; Usage Data.

    Full information about each type of Personal Data collected is provided in special sections of this Privacy Policy or in specific explanatory texts displayed before data collection. Personal data may be freely provided by the User or, if used, collected automatically during use. Unless otherwise stated, all Data used by this Site is mandatory and failure to provide this Data may make it impossible for the Site to provide its services. Users may not transfer this Data without affecting the availability or operation of the Service Users who do not know what Personal Data is required may contact the owner Any use of cookies or other tracking tools by this Application or owners of third-party services used in this Annex, serves to provide the service required by the User, in addition to any - any other purposes described in this document and in the Cookie Policy, if available.

    Users are responsible for any third-party personal data received, published or transmitted through this program, and confirm that they have the consent of a third party to provide data to the Owner.

  • Mode and place of data processing

    Processing methods

    The owner takes appropriate security measures to prevent unauthorized access, disclosure, alteration or unauthorized destruction of data. Data processing is carried out using computers and / or IT-enabled means, strictly following organizational procedures and regimes. In addition to the Owner, in some cases the Data may be made available to certain persons responsible for participating in the work of this Annex (administration, sales, marketing, legal, system administration) or to external parties (eg third parties). technical service providers, postal carriers, hosting providers, IT companies, communications agencies) designated, if necessary, by the data processors of the owner. An updated list of these parties may be requested from the owner at any time.

    Legal basis of processing

    The Owner may process Personal Data relating to Users if one of the following applies:

    • users have given their consent to one or more specific purposes. Note: According to some laws, the Owner may be allowed to process Personal Data as long as the User does not object to such processing (",refusal") any other of the following legal bases. However, this does not apply where the processing of Personal Data is governed by European data protection law;
    • the provision of Data is necessary for the performance of the agreement with the User and / or any pre-contractual obligations in this regard;
    • processing is necessary to comply with the legal obligation to which the Owner applies;
    • processing is related to a task performed in the public interest or in the exercise of state powers vested in the Owner;
    • processing is necessary for the purposes of legitimate interests pursued by the Owner or a third party.

    In any case, the Owner will be happy to help clarify the specific legal basis applicable to the processing, and in particular whether the provision of Personal Data is a legal or contractual requirement or a requirement required for the conclusion of a contract.


    Data shall be processed in the owner's operating offices and in any other place where the parties involved in the processing are located.

    Depending on the location of the User, the transfer of data may involve the transfer of User Data to a country other than their own. To learn more about the place of processing such transferred Data, Users may view the section containing details on processing Personal Data.

    Users also have the right to know the legal basis for the transfer of data to a country outside the European Union or to any international organization governed by public international law or established by two or more countries, such as the UN, and the security measures taken by the Owner.,to protect your Data.

    If such transfer takes place, Users may learn more by checking the relevant sections of this document or contacting the Owner using the information provided in the contact section.

    Retention time

    Personal data shall be processed and stored as long as required for the purpose for which they were collected.


    • Personal data collected for purposes related to the performance of the contract between the Owner and the User shall be stored until the full performance of such contract.
    • Personal data collected for the legitimate interests of the Owner shall be kept as long as necessary to achieve such purposes. Users may find specific information on the legitimate interests pursued by the Owner in the relevant sections of this document or by contacting with the Owner.

    The Owner may retain Personal Data for a longer period when the User has consented to such processing until such consent is revoked. In addition, the Owner may be obliged to keep Personal Data for a longer period when this is necessary for the performance of a legal obligation or by order of a public authority.

    Personal data shall be deleted at the end of the retention period. Therefore, the right of access, the right of erasure, the right of rectification and the right of transfer may not be ensured after the end of the retention period.

  • Processing Objectives

    Data relating to the User are collected so that the Owner can provide his service, fulfill his legal obligations, respond to requests for security, protect its rights and interests (or the interests of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Social features, Access to third-party accounts and Interaction with external social networks and platforms.

    For specific information about the Personal Data used for each purpose, the User may refer to the section "Details of the processing of Personal Data".

  • Facebook permissions requested by this application

    This application may require certain Facebook permissions that allow it to act with and obtain information from the User's Facebook account, including Personal Data. This service allows this Application to connect to the User's account on the Facebook social network. provided by Facebook Inc.

    For more information on the following permissions, see the Facebook permissions documentation and Facebook's privacy policy. The following permissions are required:

    Basic Information

    By default, this includes certain User Data, such as ID, Name, Image, Gender and Location. Certain User connections are also available, such as Friends. If the User has made more of their Data publicly available, additional information will be available.

    About me

    Provides access to the "About Me" profile section.

  • Detailed information on the processing of Personal Data

    Personal data is collected for the following purposes and using the following services:

  • User Rights

    Users may enjoy certain rights to their Data processed by the Owner.

    In particular, Users have the right to do the following:

    1. Withdraw their consent at any time. Users have the right to withdraw their consent where they have previously given their consent to the processing of their Personal Data.
    2. Objection to the processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on legal grounds other than consent. More detailed information is provided in a special section below.
    3. Access to their data. Users have the right to know whether the data is processed by the Owner, to obtain disclosure of certain aspects of processing and to obtain a copy of the data being processed.
    4. Check and seek corrections. Users have the right to check the accuracy of their Data and ask them to update or correct.
    5. Restrict the processing of their Data. Users have the right to restrict the processing of their Data in certain circumstances. In this case, the Owner will not process their Data for any purpose other than storing it.
    6. Delete their Personal Data. Users have the right to delete their Data under certain circumstances of the Owner.
    7. Receive their Data and pass it on to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically possible, to pass it on to another controller without any interference. This provision applies provided that the Data is processed by automated means and processing is carried out with the consent of the User, the contract of which the User is a part, or his pre-contractual obligations.
    8. File a complaint. Users have the right to make a claim to their competent data protection authority.

    Details of the right to object to processing

    If Personal Data is processed for the public interest, in the exercise of official authority vested in the Owner, or for the legitimate interests pursued by the Owner, Users may object to such processing by providing a basis related to their particular situation. . substantiate the objection.

    Users should be aware that, however, if their Personal Data is processed for direct marketing purposes, they may object to this processing at any time without providing any justification. To find out if the Owner processes Personal Data for For direct marketing purposes, Users may refer to the relevant sections of this document.

    How to exercise these rights

    Any requests for the exercise of the User's rights may be made to the Owner through the contact details provided in this document. These requests may be made free of charge and will be considered by the Owner as soon as possible and always within one month.

  • Additional information on data collection and processing

    Legal action

    The User's personal data may be used by the Owner for lawful purposes in court or in stages leading to possible legal action arising from the improper use of this Application or related Services. The user declares that he knows that the Owner may require the disclosure of personal data at the request of public authorities.

    Additional Information about User Personal Data

    In addition to the information contained in this Privacy Policy, this Site may provide the User with additional and contextual information relating to certain Services or the collection and processing of Personal Data on request.

    System and Service Logs

    For the purposes of operation and maintenance, this Site and any third-party services may collect files that record interaction with this site (system logs) using other Personal Data (eg IP address).

    Information not contained in this policyі

    More details on the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

    How Do Not Track Requests Are Handled

    This Site does not support the Do Not Track queries. To determine whether any third-party service it uses meets the Do Not Track queries, please read their privacy policy.

    Changes to this Privacy Policy

    The owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this site and / or - or as technically and legally as possible - by notifying Users through any contact information available to the Owner. It is strongly recommended that you check this page frequently, referring to the date of the last modification below.

    If the changes concern processing activities performed with the consent of the User, the Owner shall collect the new consent of the User, if required.

  • The document was last updated on May 17, 2021.