This Privacy Policy establishes the procedure and conditions for the collection, processing, storage, use, disclosure, transfer, protection, and other processing of Personal Data by the Company in connection with the provision of the Services, operation of the Website, business communication, consideration of inquiries, conclusion and performance of contracts, and other related interactions with Users and other persons whose Personal Data may be processed by the Company in the course of its activities.

The provisions of this Privacy Policy define the categories of Personal Data processed by the Company, the purposes and legal grounds for such processing, the sources from which Personal Data may be obtained, the persons to whom Personal Data may be disclosed, the applicable retention periods, the rights of data subjects, and other essential conditions of Personal Data processing by the Company.

For the purposes of this Privacy Policy, the terms “we”, “our”, “us” and other similar expressions shall mean the Company.

For the purposes of this Privacy Policy, the terms “you”, “your”, “User” and other similar expressions shall mean any individual who accesses, uses, orders, receives, requests, or otherwise interacts with the Services, the Website, the Company, or the functionality made available by the Company, as well as, where applicable under the context, a representative of a legal entity or another person acting in the interests of a User or potential client.

References in this Privacy Policy to words in the masculine, feminine or neuter gender, as well as in the singular or plural, shall be interpreted equally and interchangeably, depending on the context, and shall not affect the interpretation of the provisions of this Privacy Policy.

By accessing the Website, using the Services, submitting an inquiry, communicating with the Company, or otherwise interacting with the Company in any form, you acknowledge that you have read this Privacy Policy and understand the general principles under which the Company processes Personal Data.

The words he/she and their derivatives in the text of the document can be applied to either a male person or a female person, depending on the context of the document.

We are grateful to you for using the Company's services.

1. DEFINITIONS 

1. Personal Data means any information relating to a natural person who is identified or can be identified, directly or indirectly, including by reference to an identifier or to one or more factors specific to that person. For example, first name, last name, phone number, and IP address.

2. Services means the services provided by the Company in the field of information technology, including, among other things, software development, mobile application development, web development, implementation of technical solutions, maintenance, support, integration, customization, testing, consulting, and other related services offered by the Company to the User.

3. Company's website (hereinafter referred to as the "Website") means a web page or a group of web pages on the Internet located at: https://smediaweb.com/en/ 

4. Company (hereinafter referred to as the "Company" or "SMEDIA" ) means, as applicable, Limited Liability Company “SMEDIA GROUP”, a legal entity incorporated and existing under the laws of Ukraine, EDRPOU Code: 42341212, registered address: 112D Naberezhna Peremohy Street, Building 3, Office 3, Dnipro, Dnipropetrovsk Region, Ukraine, 49100, and/or SMEDIAWEB LTD, a company incorporated and existing under the laws of England and Wales, company registration number: 15127386, registered address: 128 City Road, London, United Kingdom, EC1V 2NX, which may provide the Services to Users in accordance with the applicable agreements, terms, policies, and other contractual documents.

5. User means any natural person or legal entity that accesses the Website, requests, receives, uses, or otherwise interacts with the Services, as well as, where applicable, any representative acting on behalf of such natural person or legal entity.

6. Third Party means any natural person, legal entity, public authority, agency, institution, contractor, service provider, or other body other than the User, the Company, the Controller, or the Processor.

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

8. 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.

9. Cookies means small text files, technical identifiers, or similar technologies that are stored on, transmitted to, or accessed from the User’s device or browser when the User accesses or uses the Website, for the purpose of enabling, maintaining, analyzing, securing, or improving the operation of the Website and related functionality.

10. User's Consent (hereinafter "Consent") means any freely given, specific, informed, and unambiguous indication of the User’s wishes by which the User, by a statement or by a clear affirmative action, signifies agreement to the processing of Personal Data relating to such User.

2. GENERAL PROVISIONS

1. The Company provides Services to Users located in different jurisdictions and may, in the course of its activities, be subject to the requirements of the laws and regulations applicable in the respective jurisdictions, including, where applicable, data protection and privacy laws.

2. This Privacy Policy applies to the processing of Personal Data carried out by the Company in connection with the operation of the Website, business communication, receipt and review of inquiries, pre-contractual interaction, conclusion and performance of contracts, provision of the Services, and other related activities of the Company.

3. Depending on the nature of the relevant relationship, the category of Personal Data, the source from which such Personal Data is obtained, and the purposes for which such Personal Data is processed, the Company may act either as a Controller or as a Processor.

4. The Company acts as a Controller where it independently determines the purposes and means of processing Personal Data, including, among other things, where it processes Personal Data collected through the Website, communication channels, contractual relations, invoicing, business administration, compliance procedures, marketing activities, and other operations relating to its own business activities.

5. The Company acts as a Processor where it processes Personal Data on behalf of and under the instructions of its client in the course of providing the Services, including where such processing is necessary for the performance, support, maintenance, implementation, integration, testing, customization, or other technical execution of the Services requested by such client.

6. In cases where the Company acts as a Processor, the scope, purpose, categories, duration, and other conditions of the relevant processing of Personal Data may be additionally governed by the applicable contract, data processing agreement, service agreement, or other binding arrangement concluded between the Company and the relevant Controller.

7. The Company processes Personal Data in accordance with this Privacy Policy, the applicable agreements, and the requirements of applicable law, and applies the approach to such processing that corresponds to the legal status in which the Company acts in each particular case.

8. This Privacy Policy may be used and applied by both Limited Liability Company “SMEDIA GROUP” and SMEDIAWEB LTD in connection with the provision of the Services, communication with the User, operation of the Website, and other activities related to the Services. Each of these companies may act in accordance with this Privacy Policy where it participates in the relevant interaction with the User, receives or processes Personal Data, provides the Services, communicates with the User, issues documents, or otherwise acts in connection with the Services. For the purposes of this Privacy Policy, references to the Company shall mean the company that actually participates in the relevant interaction with the User, or both companies where Limited Liability Company “SMEDIA GROUP” and SMEDIAWEB LTD jointly participate in such interaction.

3. PERSONAL DATA

1. The Company may receive the following Personal Data about the Users (individual person):

1. full name;

2. phone number;

3. email address;

4. geolocation;

5. location and registration address.

2. The Company may receive the following Personal Data about the Users (individuals or employees of a legal entity acting as a Users):

1. full name;

2. phone number;

3. email address;

4. job title or position.

3. The Service may collect the following Statistical Data about the User (legal entity):

1. company information: name, registered address, business structure, country of registration and operation, IBAN, business sector, information about staff and management, etc.;

2. registration/tax number;

3. contact details: phone number, email address, etc.;

4.  payment/banking details used solely for the receipt of Service payments.

4. The Company purposefully does not process the User's banking data, and such data is processed exclusively by the payment system, which is used to receive payments. The Company may process payment data solely to resolve disputes and/or to comply with the requirements of the legislature and/or the decision of the judicial/executive authority.

5. Personal Data may also be processed by the Company where such processing is necessary for the preparation, conclusion, performance, administration, amendment, or termination of a contract for the provision of the Services, including where such Personal Data is provided to the Company by the User or otherwise becomes available to the Company in connection with the provision of the Services under such contract.

6. The Company 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.

7. When visiting the Site or receiving Services, Company may collect the following Personal Data automatically:

1. IP address;

2. time zone and language settings;

3. browser type and version;

4. operating system, device type, and screen extension;

5. the country in which you are located;

6. data about your visit to the Site, including full URL information, routes to and from the Site (including date and time), page response time, data loading errors, length of stay on certain pages, page activity (such information such as scrolling and mouse movements, clicks), methods used to exit the page and telephone numbers to contact the User'  support.

8. The Company has the right to collect and receive Personal Data as follows:

1. when the User submits a request, inquiry, or other information through the Website or otherwise contacts the Company;

2. when the Company communicates with the User in connection with a potential cooperation, conclusion of a contract, or provision of the Services;

3. when the Company provides the Services to the User;

4. through the use of log files, Cookies, and other tracking technologies in connection with the operation and use of the Website.

9. The Company has the right to use Personal Data for the following purposes to:

1. review, process, and respond to requests, inquiries, and other communications received from the User;

2. communicate with the User in connection with a potential cooperation, conclusion of a contract, provision of the Services, or other related matters;

3. conclude, perform, administer, and support contracts and other business relationships with the User;

4. provide the Services to the User;

5. operate, maintain, administer, protect, and improve the Website and the Company’s business processes;

6. ensure the security, integrity, and proper functioning of the Website and related systems;

7. carry out internal administrative, technical, and operational activities, including troubleshooting, testing, analysis, and improvement of the Services and the Website;

8. comply with applicable legal, regulatory, and contractual requirements;

9. respond to lawful requests of competent authorities;

10. establish, exercise, protect, or defend the Company’s rights and legitimate interests, including in connection with claims, disputes, investigations, or legal proceedings.

4. TRANSFER OF PERSONAL DATA

1. The Company may transfer Personal Data to entities with which the Company cooperates in the implementation and provision of Services:

1. Payment services and banks — in connection with the processing of payments for the Services, including receipt of payments, issuance of refunds, or verification of financial transactions. In such cases, the processing of Data is carried out in accordance with the privacy policy of the respective payment service provider or banking institution.

2. Contractors, partners, and employees of the Service — in cases where this is necessary for the provision of professional or technical services to the Service, such as legal, accounting, financial, tax, marketing, logistics, administrative, or IT support. These persons act on the basis of data processing agreements and are obligated to ensure the confidentiality and security of the transferred Data.

3. Counterparties in connection with corporate events — including within the scope of mergers, acquisitions, reorganizations, financing, asset sales, establishment of joint ventures, or during bankruptcy proceedings. In such cases, the transfer of Data is carried out in accordance with the applicable legal requirements while observing the rights of the User.

4. Authorized government bodies, courts, law enforcement agencies — in cases where such transfer is mandatory in accordance with legal requirements, in particular on the basis of a court decision, request from an authorized government authority, or other procedures provided by law.

5. Between the companies. Personal Data may be disclosed between Limited Liability Company “SMEDIA GROUP” and SMEDIAWEB LTD where such disclosure is necessary for communication with the User, consideration and processing of requests, preparation and performance of agreements with the User, provision of the Services, technical support, project administration, invoicing, security, compliance, or protection of the rights and legitimate interests of the Company. Such disclosure shall be limited to the scope necessary for the relevant purpose and shall be carried out subject to applicable confidentiality, data protection, and security obligations.

2. All Data transfers are carried out in compliance with the principles of data minimization, lawfulness, proportionality, and appropriate protection of Data in accordance with the provisions of this Policy and applicable data processing legislation.

5. USER CONSENT

1. Where the processing of Personal Data is based on Consent, the User provides voluntary, informed, specific, and unambiguous Consent to the processing of Personal Data in accordance with this Privacy Policy by performing any of the following actions:

1. submitting a request, inquiry, contact form, application, message, or other information to the Company through the Website;

2. confirming familiarity with this Privacy Policy by checking the corresponding box, clicking the relevant confirmation button, or performing another clear affirmative action through the Website or other technical means;

3. providing Personal Data to the Company by email, telephone, messenger, online form, or another communication channel for the purpose of requesting information about the Services, negotiating cooperation, concluding a contract, or receiving the Services;

4. giving a separate consent to the use of Cookies, analytics tools, or other tracking technologies, where such consent is required by applicable law.

2. Consent is granted only for the specific processing purposes for which it has been requested or provided. The provision of Consent does not limit the Company’s right to process Personal Data on other lawful grounds where such processing is necessary for the preparation, conclusion, performance, administration, amendment, or termination of a contract, compliance with applicable legal obligations, protection of the Company’s rights and legitimate interests, or for other grounds permitted by applicable law.

3. By giving Consent to the processing of Personal Data, the User confirms that the User has read this Privacy Policy and understands that Personal Data may be processed by the Company for the following purposes:

1. receiving, reviewing, and responding to the User’s requests, inquiries, messages, or other communications;

2. communicating with the User regarding the Services, potential cooperation, contractual relations, technical matters, commercial proposals, or other related issues;

3. preparing, concluding, performing, administering, amending, or terminating contracts for the provision of the Services;

4. providing the Services to the User, including software development, application development, web development, technical support, integration, consulting, maintenance, and other related information technology services;

5. operating, maintaining, protecting, and improving the Website, the Services, and the Company’s internal business processes;

6. using Cookies, log files, analytics tools, or other tracking technologies in connection with the operation of the Website, where such processing is carried out on the basis of the User’s Consent;

7.  sending marketing, informational, or commercial communications, where the User has provided separate Consent to receive such communications;

8. complying with applicable legal requirements, responding to lawful requests of competent authorities, and protecting the rights, legitimate interests, and legal position of the Company.

4. The Company reserves the right to obtain the User's Consent via the Pop-up form. The Pop-up form may contain a Consent form in the сheckbox view.

6. PERSONAL DATA STORAGE AND PROTECTION 

1. The Company uses all necessary security and protection measures for Personal Data to ensure their confidentiality and prevent loss or improper disclosure.

2.  The Company protects and stores Personal Data from:

1. losses;

2. unlawful use, transfer, disclosure, modification, deletion, and/or destruction.

3. We may use the following methods to protect Personal Data in accordance with the article "Security of processing" 32 GDPR:

1. pseudonymization and encryption of Personal Data;

2. ability to ensure constant confidentiality, integrity, availability and fault tolerance of Personal Data processing systems;

3. regular testing, evaluation and measurement of the effectiveness of technical and organizational measures to ensure the security of processing Personal Data.

4.  The Company does not store the User'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.

5. Company has the right to retain Personal Data of User for 3 (three) years after the termination of the relationship in the following cases:

1. for statistical accounting;

2. if the current legislation requires their storage;

3. if they are necessary for doing business.

6. The Company maintains and applies an internal Security Policy for the protection of Personal Data processed in connection with the Website, business communications, and the provision of information technology services, including software development, application development, web development, technical support, integrations, testing, maintenance, and related services. The Security Policy defines internal rules for access to Personal Data, confidentiality, secure handling of information received from Users, use of systems and communication channels, prevention of unauthorized access, and response to security incidents.

7. The Company ensures that its employees, contractors, subcontractors, consultants, developers, technical specialists, and other persons engaged by the Company who may have access to Personal Data in connection with the provision of the Services are bound by a Data Processing Agreement, confidentiality undertaking, or other written data protection obligations, as applicable. Such persons may process Personal Data only to the extent necessary for the performance of the Services and only in accordance with the Company’s instructions, this Privacy Policy, the applicable contract, and applicable data protection requirements.

7. GROUNDS FOR PERSONAL DATA PROCESSING

1. The Company processes Personal Data only where there is a lawful ground for such processing under applicable data protection laws.

2. The Company may process Personal Data on the following grounds:

1. User’s Consent, where the User has given voluntary, specific, informed, and unambiguous Consent to the processing of Personal Data for one or more specific purposes;

2. performance of a contract, where the processing of Personal Data is necessary for the preparation, conclusion, performance, administration, amendment, or termination of a contract for the provision of the Services;

3. pre-contractual communication, where the processing of Personal Data is necessary to review the User’s request, respond to an inquiry, prepare a commercial proposal, discuss the scope of Services, or take other steps at the User’s request before entering into a contract;

4. compliance with legal obligations, where the processing of Personal Data is necessary for the Company to comply with applicable legal, regulatory, accounting, tax, reporting, or other mandatory requirements;

5. legitimate interests of the Company, where the processing of Personal Data is necessary for the proper conduct of the Company’s business, communication with Users, administration and protection of the Website, provision and improvement of the Services, prevention of unlawful actions, protection of the Company’s rights and interests, handling of claims, disputes, investigations, or legal proceedings, provided that such interests are not overridden by the rights and freedoms of the User;

6. processing on behalf of the User or another Controller, where the Company processes Personal Data as a Processor in connection with the provision of information technology services, including software development, application development, web development, technical support, integrations, testing, maintenance, or related services, and such processing is carried out in accordance with the applicable contract, data processing agreement, and instructions of the relevant Controller.

3. Where the processing of Personal Data is based on Consent, the User has the right to withdraw such Consent at any time by sending a request to the Company at: contact@smediaweb.com

4. Withdrawal of Consent does not affect the lawfulness of processing carried out on the basis of Consent before its withdrawal. Withdrawal of Consent also does not affect the Company’s right to continue processing Personal Data where such processing is based on another lawful ground, including performance of a contract, compliance with legal obligations, protection of the Company’s rights and legitimate interests, or processing required for the establishment, exercise, or defense of legal claims.

5. If Consent is withdrawn and the relevant processing is necessary for communication with the User, consideration of the User’s request, use of the Website, or provision of the Services, the Company may be unable to continue the relevant communication, process the request, provide the relevant functionality, or provide the Services in whole or in part.

6. The Company shall cease processing Personal Data based on withdrawn Consent within 15 (fifteen) business days from the date of receipt of the withdrawal request, unless continued processing is required or permitted under another lawful ground.

8. USER RIGHTS (JURISDICTION OF UKRAINE)

1. This section of the Privacy Policy governs the processing of Data belonging to Users who are residents of Ukraine, in accordance with the requirements of the legislation of Ukraine, in particular the Law of Ukraine "On Personal Data Protection," as well as within the scope of provisions consistent with the principles of international law and best practices for personal data processing.

2. The provisions of this section apply to Users and address specific requirements in accordance with the legislation of Ukraine, particularly the Law of Ukraine "On Personal Data Protection." Users are entitled to the following rights to:

1. receive information about the conditions for granting access to their Personal Data, including information about Third Parties to whom such data is transferred

2. receive information, no later than thirty (30) calendar days from the date of receipt of the request (except as provided by law), as to whether their Personal Data is being processed;

3. submit a reasoned request objecting to the processing of Personal Data;

4. submit a reasoned request for the modification or deletion of Personal Data;

5. the protection of Personal Data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as protection from the provision of false information or information that defames the honor, dignity, or business reputation of the User;

6. file complaints with the court regarding the processing of Personal Data;

7. apply legal remedies in case of violations of the legislation on personal data protection;

8. include reservations regarding the limitation of the right to process Personal Data when giving Consent;

9. withdraw Consent to the processing of Personal Data;

10. know the mechanism of automatic processing of Personal Data;

11.  protection from automated decisions that have legal consequences for the User.

9. USER RIGHTS

1. This section of the Privacy Policy governs the processing of Data belonging to Users who are residents of the member states of the European Economic Area (EEA), in accordance with the provisions of the General Data Protection Regulation (Regulation (EU) 2016/679, GDPR). The processing of such Users’ Data is carried out on lawful grounds and in compliance with the principles of lawfulness, transparency, proportionality, purpose limitation, and data minimization as set forth by the GDPR.

2. When processing personal and statistical data, the Service grants the User the following rights:

1. Right of access (Article 15 GDPR). The User may contact us directly to access the Data we hold about them, as well as any additional information provided for in Article 15 of the General Data Protection Regulation (GDPR).

2. Right to erasure (Article 17 GDPR). The User has the right to request the deletion of their Data. In such a case, the Data will be permanently deleted in accordance with Article 17 GDPR, unless legal exceptions apply.

3. Right to data portability (Article 20 GDPR). The User has the right to receive their Data in a structured, commonly used, and machine-readable format and to transmit it to another controller or request its direct transmission to a third party, where technically feasible, pursuant to Article 20 GDPR.

4. Right to rectification (Article 16 GDPR). The User has the right at any time to request the update, correction, or completion of inaccurate or incomplete Data in accordance with Article 16 GDPR.

5. Right to object (Article 21 GDPR). The User has the right to object at any time to the processing of their Data on grounds relating to their particular situation, pursuant to Article 21 GDPR.

6. Automated individual decision-making, including profiling (Article 22 GDPR). The User has the right not to be subject to a decision based solely on automated processing, including profiling, if such a decision produces legal effects concerning them or similarly significantly affects them, as set forth in Article 22 GDPR.

10. USER RIGHTS (USA)

1. This section of the Privacy Policy regulates the procedure for processing personal data of Users who are residents of the United States of America, taking into account the requirements of the legislation of individual U.S. states on the protection of personal information, in particular the California Consumer Privacy Act (CCPA/CPRA).

2. This section applies to Users who are residents of the United States of America. Within the framework of applicable legislation, including the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), Users have the right to exercise the following rights with respect to their Personal Data:

1. Right of access. The User has the right to request which Personal Data about them is stored by the Service, as well as to learn about the purpose of its processing, its source, and the categories of third parties to whom it may have been disclosed.

2. Right to deletion. The User has the right to request full deletion of their Personal Data, except in cases where its retention is necessary under applicable law.

3. Right to rectification. The User has the right to update, change, or supplement inaccurate or incomplete Personal Data stored by the Service.

4. Right to data portability. The User has the right to receive a copy of their Personal Data in a commonly used machine-readable format and to transfer this data to another service provider upon request.

5. Right to object. The User may object at any time to the processing of their Personal Data, including for marketing or analytical purposes.

6. Right to withdraw consent. The User has the right to withdraw previously given consent to the processing of Personal Data. In such a case, the Service reserves the right to discontinue the provision of Services.

3. The Service does not support the "Do Not Track" (DNT) signal, in accordance with the California Online Privacy Protection Act (CalOPPA). DNT is a browser setting that allows Users to notify websites that they do not wish to be tracked. The User can enable or disable the DNT feature in their web browser settings.

11. SUBMISSION OF REQUEST

1. A User in any jurisdiction has the right to submit a request to the Company if he believes that his rights have been violated by writing a request in writing to the support of the Company at the address: contact@smediaweb.com

2. The User's request must contain accurate information about the requirements for the Company. If the exact requirements are not specified in the request, the Company has the right to refuse to fulfill the request.

3. We will not be able to respond to your request or provide you with Personal Data unless we can verify your identity and confirm that the Personal Data belongs to you. In case of receiving a request with inaccurate information and/or in case of inability to confirm the User's identity, the Company has the right not to process the received request and contact the User for clarification. In case of receiving a response to a request for clarifications, the User must provide a new corrected request or submit a new request.

4. The Company must respond to the request or fulfill the conditions set forth in the request within 21 (twenty one) business days from the moment of its receipt.

12. RESPONSIBILITY

1. The Company informs the User that certain Personal Data may be necessary for communication with the User, consideration of the User’s requests, preparation, conclusion and performance of contracts, provision of the Services, operation of the Website, and compliance with applicable legal requirements. If the User does not provide Personal Data that is necessary for such purposes, or objects to the processing of such Personal Data where such processing is required for the provision of the Services, the Company may be unable to provide the Services in whole or in part.

2. The User is responsible for the accuracy, completeness, and relevance of the Personal Data provided to the Company. The Company is not responsible for the consequences arising from the provision of inaccurate, incomplete, outdated, or misleading Personal Data by the User.

3. The Company is not responsible for the processing of Personal Data by Third Parties where such processing is carried out independently by such Third Parties and is not under the control of the Company, except where otherwise required by applicable law.

4. The Website may contain links to third-party websites, platforms, tools, or services. The privacy practices, data processing procedures, security measures, and content of such third-party websites, platforms, tools, or services are not governed by this Privacy Policy. The Company is not responsible for the processing of Personal Data by such third parties, unless such responsibility is directly established by applicable law.

5. The Company is not responsible for unauthorized access, unlawful processing, loss, disclosure, alteration, deletion, or destruction of Personal Data caused by the actions or omissions of the User, Third Parties, service providers acting independently from the Company, or other circumstances beyond the reasonable control of the Company, except where such consequences were caused by the Company’s breach of applicable data protection requirements.

6. The User acknowledges that transmission of information through the Internet, electronic communication channels, websites, online forms, email, messengers, and other digital means cannot be guaranteed as completely secure. The Company applies appropriate technical and organizational measures to protect Personal Data; however, the Company cannot guarantee absolute security of Personal Data during transmission through channels that are not fully controlled by the Company.

7. Nothing in this Privacy Policy excludes or limits the Company’s liability where such liability cannot be excluded or limited under applicable law.

13. COOKIES

1. The Company may use Cookies, log files, technical identifiers, and similar tracking technologies in connection with the operation, maintenance, security, analysis, and improvement of the Website.

2. Cookies may be used by the Company for the following purposes to:

1. ensure the proper technical operation of the Website;

2. maintain the security and integrity of the Website;

3. remember the User’s preferences, where applicable;

4. analyze the use, performance, and functionality of the Website;

5. identify technical errors, prevent abuse, and improve the User’s interaction with the Website;

6. support communication with the User and processing of inquiries submitted through the Website.

3. The Company may use the following categories of Cookies:

1. strictly necessary Cookies, which are required for the operation of the Website and cannot be disabled without affecting the functionality of the Website;

2. functional Cookies, which allow the Website to remember certain choices or preferences of the User, where such functionality is available;

3. analytics Cookies, which help the Company understand how Users interact with the Website, assess Website performance, detect technical issues, and improve the Website and the Services;

4. marketing or tracking Cookies, where such Cookies are used by the Company or Third Parties for marketing, advertising, remarketing, or similar purposes, subject to the User’s Consent where such Consent is required by applicable law.

4. The Company may also use Third-Party services that place or access Cookies, technical identifiers, pixels, scripts, or similar technologies through the Website. Such Third Parties may process data collected through these technologies in accordance with their own privacy policies and terms, unless they act on behalf of the Company under the applicable contractual arrangements.

5. Where required by applicable law, the Company obtains the User’s Consent before placing or using non-essential Cookies, including analytics, marketing, advertising, remarketing, or similar tracking technologies.

6. The User may manage, block, delete, or restrict Cookies through the settings of the User’s browser or device. The User may also use the Cookie management tools made available on the Website, where such tools are implemented by the Company.

7. If the User disables or restricts Cookies, certain functions of the Website may become unavailable, operate incorrectly, or provide a limited user experience.

8. The Company may update the information regarding the use of Cookies if the Website functionality, technical tools, analytics systems, advertising technologies, or Third-Party services used by the Company are changed.

9. The Company can use the following web analytics services:

1. Facebook;

2. Google Analytic.

14. CONFIRM POLICY

1. The Website and the Services are intended for Users who have the legal capacity and authority to request, negotiate, order, receive, or otherwise interact with the Company in connection with the provision of information technology services, including software development, application development, web development, technical support, integrations, maintenance, consulting, and related services.

2. Where the User acts through a representative, employee, contractor, manager, director, or other authorized person, such person confirms that he or she has the necessary authority to act on behalf of the User, provide information to the Company, communicate regarding the Services, negotiate contractual terms, and submit documents or other materials required for cooperation with the Company.

3. The Company may request information or documents reasonably necessary to verify the User, the authority of the person acting on behalf of the User, the User’s legal capacity, and the possibility of entering into or performing a contract with the User. If the User fails to provide such information, provides inaccurate information, acts without proper authority, or does not have the required legal capacity, the Company may refuse further communication, decline the request, suspend contract preparation, refuse to provide the Services, or terminate the relevant interaction.

15. PRIVACY POLICY CHANGE

1. We have the right to periodically make changes to the Privacy Policy, the security of Personal Data, and compliance with the requirements of the laws of the jurisdiction in which we operate.

2. The User is obliged to familiarize himself with the new terms of the Privacy Policy and the Company is not responsible if the User has not familiarized himself with the new terms of the Privacy Policy.

3. The Company updates the date of changes to the current version of the Privacy Policy in the "Updated" line at the top of the document.

4. Our digital or otherwise stored copies of the Privacy Policy are considered true, complete, valid, and enforceable and in effect, at the time you visit the Website.

16. CONTACTS

1. The User has the right to contact the Company support service at: contact@smediaweb.com to ensure his rights, in accordance with the terms of this Privacy Policy, or in case of violation of his rights, or to leave feedback or ask a question.