1. General Provisions
This Privacy Policy and Personal Data Protection Policy (hereinafter referred to as the "Privacy Policy") sets out how we, LLC "Horoshop", identification code 43218562, a legal entity registered and operating in accordance with the requirements of Ukrainian legislation (hereinafter - the “Company”), operate the Company’s website https://cartum.io (hereinafter referred to as the "Platform") and protect your personal data that you provide to us, or that is otherwise obtained or generated by us. For the purposes of this Privacy Policy, ‘we’, ‘us’ and ‘our’ refers to the Company and ‘you’ refers to you, the user of the Company’s website.
This Privacy Policy establish the procedure for the Company's processing of personal data, the types of personal data collected, the purpose of using such personal data, the Company's interaction with third parties, security measures to protect personal data, conditions for access to personal data, as well as contact information for users to access, make changes, block or delete their personal data, and address any questions that may arise regarding the practice of personal data protection.
This Privacy Policy shall be deemed also the privacy notice, i.e. this Privacy Policy is our (data controller and processor) statement to you (data subject) that describes how we collect, use, retain and disclose personal data.
This Privacy Policy applies to the data we may obtain from third parties.
2. Legal Ground for Processing Your Personal Data
We process your personal data on the ground that such processing is necessary to further our legitimate interests (including: (1) providing effective and innovative Services to our users; and (2) to detect, prevent or otherwise address fraud or security issues in respect of our provision of Services), unless those interests are overridden by your interest or fundamental rights and freedoms that require protections of personal data.
3. Collection and Use of Personal Data
The owner and manager of users' personal data on the Platform is LLC "Horoshop".
If you are a seller using the Platform to develop your business, we may collect the following information about you:
| Data we collect | Reason for data collection |
| The information you provide us about yourself and your business, such as your name, company name, address, email address, and phone number. |
1. To provide you with the use of our platform and other related services (for example, to confirm your identity, contact you regarding platform-related issues, invoice you). 2. For advertising and marketing of products or features to you. 3. To comply with legal requirements |
| Information about how you access Cartum websites, your account, and our platform, including information about the device and browser you use, your network connection, your IP address, and details about how you browse our websites and platform. We collect some of this information using cookies or similar technologies directly from your device. |
1. To provide you with the opportunity to use our platform and other related services and improve it (for example, identify ways to simplify the use or navigation of our platform). 2. To personalize the platform for you (for example, display a data grid in the admin panel with settings chosen by you). 3. For advertising and marketing of products or features to you. |
| Copies of government-issued identification documents that you provide to us. |
1. If it's necessary for us to verify your identity (for example, to protect you from theft or fraud). 2. To ensure that we are speaking with you if you contact us. 3. To comply with legal requirements. |
| If you use our Reports and have granted our application access to Google Analytics, we may collect information about the number of views on your website for a certain date. | To provide you with the ability to use all types of our Reports (for example, display conversion funnels in the Reports). |
If you are a client using services, making purchases, or visiting an online store on the Platform, we may collect the following information about you:
| Data we collect | Reason for data collection |
| Information that you provide about yourself, such as your name, shipping address, email address, phone number, and payment information | Provide our services to sellers and enable them to manage their business, for example, so that they can conduct transactions, fulfill orders, and communicate with you regarding new products or offers. |
| If you register or log in to the Platform's account through Google, Facebook, Linkedin accounts, we may collect information related to your profile, namely: name, email address, profile photo. | Provide our services to sellers and enable them to manage their business, for example, so that they can carry out transactions, fulfill orders, and communicate with you regarding new products or offers |
| Information about how you access Cartum websites, your account, and our platform, including information about the device and browser you use, your network connection, your IP address, and details about how you browse our websites and platform. We collect some of this information using cookies or similar technologies directly from your device. | Provide sellers with our services and give them the ability to manage their business (for example, provide them with analytics on how many people visit their store and help them identify shortcomings to improve their store). |
If you are a visitor to the website https://cartum.io/, we may collect the following information about you:
|
Data we collect |
Reason for data collection |
|
Information about yourself that you provide to us, such as your name, address, email address, and phone number. |
1. To provide you with the opportunity to use and enhance the application or service you are trying to use (for example, contacting you regarding the sale of the Platform's online store in response to a submitted request). 2. For advertising and marketing of products or features to you. |
|
Information on how you access Cartum websites, your account, and our platform, including details about the device and browser you use, your network connection, your IP address, and information about how you browse our websites and platform. We collect some of this information using cookies or similar technologies directly from your device. |
1. To ensure your use of our websites and associated services and to improve them (for example, identifying ways to simplify the use or navigation on our platform). 2. For advertising and marketing of products or features to you. |
When using specific services of the Platform (for example, authorization through Facebook), we may require additional information about you. The specific information and how we will use it will be described in the request confirmation window.
4. Processing and Storage of the Personal Data
Processing and storage of provided personal data are carried out in data centers where equipment ensuring the functioning of the Platform's services is located. The provided personal data is processed and may be stored in the Personal Data Base or in a separate table of the Platform's Database.
The location for storage and processing of personal data is at: OVH, Roubaix, France, 2 Rue Kellermann, 59100.
5. Retention Period of Personal Data
Personal data is stored for a period no longer than necessary for the purpose of their processing.
After the individual ceases to be a user of the Platform, their personal data is automatically deleted.
To delete your personal data, revoke consent for the processing of personal data processed by the Company, please contact the Company via email at support@cartum.io or write a letter to the address: 03189, Ukraine, Kyiv, Yulii Zdanovskoi street, 56, office 45.
6. Security of Minors
The site is not intended for underage users. The Company takes security matters very seriously, especially regarding individuals who have not reached the age of majority. As such, the Company urges parents to explain to their children internet safety issues, their specific purpose, and the necessity of using certain services of the Platform.
7. Interaction of the Company with Third Parties Regarding Personal Data
The Company does not transfer personal data to third parties except when such transfer is required by law, at the request of the data subject, or in other cases outlined in this Policy. The Company understands that personal information is valuable and an integral part, including personal non-property rights of any individual, therefore takes all possible measures to protect users' personal information voluntarily and knowingly provided to the Company.
The Site may contain links to other websites (solely for informational purposes). When following links to other websites, the terms of this Policy will not apply to those sites. Therefore, the Company recommends reviewing the privacy and personal data policies of each site before providing any personal data by which you may be identified.
8. Confidentiality of Personal Data Subject's Activity on the Site
Information about users' activity (traffic) on the Site passing through the network or user email is protected in accordance with the law. In other words, the Company does not in any way or manner breach the confidentiality of the user's 'activity' when using the Site's services.
9. Protection of Personal Data
The Company employs commonly accepted standards for technological and operational protection of information and personal data against loss, misuse, alteration, or destruction. However, despite all efforts, the Company cannot guarantee absolute protection from any threats that may arise beyond the Company's control.
The Company ensures compliance with confidentiality obligations and applies technical and organizational security measures to prevent unauthorized or unlawful disclosure or processing of such information and data, their accidental loss, destruction, or damage.
Access to information and personal data is granted only to authorized employees who have agreed to maintain the confidentiality of such information and data in accordance with the Company's requirements.
Disclosure of personal data without the consent of the data subject or their authorized representative is permitted only in cases defined by law.
10. Terms of Access to Personal Data
The procedure for accessing the personal data of third parties is determined by the terms of consent provided by the data owner for the processing of such data or in accordance with legal requirements.
A user has the right to obtain any information about themselves from any entity involved in relations related to personal data, provided they specify their full name, residence (place of stay), and details of the document identifying the individual making the request, except as established by law.
The user's access to their own data is provided free of charge.
The deferral of a user's access to their personal data is not permitted.
Deferral of access to the personal data of third parties is allowed if the necessary data cannot be provided within thirty calendar days from the date of the request. In this case, the total period for resolving issues raised in the request should not exceed forty-five calendar days.
Notification of a deferral is communicated to the attention of the third party who submitted the request, in writing, with an explanation of the procedure for appealing such a decision.
11. Your privacy rights
We, as a service provider, meet the best global practice in data protection (GDPR) and present the rights stipulated there.
You, as subjects of personal data, have the following rights:
|
Right |
Description |
|
The right to access |
You can request an explanation of the processing of your personal data |
|
The right to portability |
You can request all the data that you provided to us, as well as request to transfer data to another controller |
|
The right to restrict processing |
You may partially or completely prohibit us from processing your personal data |
|
The right to file complaints |
You can file a complaint to the regulatory body |
|
The right to be forgotten |
You can send us a request to delete your personal data from our systems unless there is a legal requirement to keep it |
|
The right to withdraw consent |
For data that you have previously consented to, you can always withdraw your consent, and we will stop processing it |
Please note! We may ask you to verify your identity before responding to a request.
You are also entitled to:
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protection of your personal data;
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application of legal remedies;
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to know the mechanism of automatic processing of personal data;
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protection against an automated decision that has legal consequences for you.
To update, access, modify, block, or delete your personal data, revoke your consent for the processing of personal data provided by you to the Company in accordance with this Policy, or in case of any comments, requests, or claims regarding your personal data processed by the company, please contact the Company via email at support@cartum.io or write a letter to the address: 03189, Ukraine, Kyiv, Yulii Zdanovskoi street, 56, Office 45.
12. Changes to this Privacy Policy
We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.
13. Questions and concerns
If you have any questions about privacy and our data policies, please contact our support@cartum.io.
14. Cookie Files
What are cookies?
Cookie files are small text files placed on the device you use to access the Platform's websites. They contain information collected from your device and sent back to the sites upon each subsequent visit to remember your actions and preferences over time.
What cookies do we use and why?
The following types of cookie files are used on the Sites:
-
Strictly necessary cookies / Technical cookies: These cookies are necessary for the operation of the Platform and to provide you with all its features. Among other things, they allow the Platform to identify your hardware and software, including your browser type.
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Statistical / Analytical cookies: These cookies recognize users, count their numbers, and collect information, such as your operations on the platform's sites, including information about the web pages you visited and the content you received.
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Technical cookies: These cookies collect information about how users interact with the Platform, allowing the detection of errors and testing new features to improve Platform performance.
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Functional cookies: These cookies enable certain functions to facilitate your use of the Platform's sites, such as saving your preferences (e.g., selected language).
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(Third-party) Tracking / Advertising cookies: These cookies gather information about users, traffic sources, visited pages, and ads displayed to you, as well as the source through which you accessed the advertised page. They enable displaying ads that might interest you based on the analysis of Personal Information collected about you. They are also used for statistical and research purposes.
When sellers use our platform for their online stores, we place the following cookie files for sellers and visitors to their stores:
Cookies Necessary for Store Functionality
|
Name of the Cookie |
Purpose |
|
PHPSESSID |
It is used to indicate the session identifier stored on the web server. |
In the Platform's stores, we use tools from the following third parties that may place cookies:
We use in stores:
|
Third party |
Description |
Privacy policy |
|
Intercom |
We use Intercom to manage our interactions with customers. |
Additionally certain third-party tools might be utilized by sellers in their stores. The list of these tools may be published by the respective sellers in their stores.
When visitors enter the site https://cartum.io, we place the following cookies:
Cookie, necessary for the site’s functioning
|
Cookie name |
Purpose |
|
PHPSESSID |
Used to indicate the session identifier, stored on the web server. |
|
slang |
Used to indicate the translation variant of interfaces displayed to the user. |
Cookie for reporting and analytics
|
Cookie name |
Purpose |
|
sbjs_current |
Used to determine the source of traffic. |
|
sbjs_current_add |
Used to determine the source of traffic. |
|
sbjs_first |
Used to determine the source of traffic. |
|
sbjs_first_add |
Used to determine the source of traffic. |
|
sbjs_migrations |
Used to determine the source of traffic. |
|
sbjs_session |
Used to determine the source of traffic. |
|
sbjs_udata |
Used to determine the source of traffic. |
We also use pixels, tags, and other tools from the following third parties on the site https://cartum.io, which may, in turn, place cookies:
|
Third party |
Description |
Privacy Policy/Cookies Policy |
|
|
We use Google Analytics, Google Tag Manager, Google Ads to evaluate how users interact with the site. |
|
|
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We use Facebook Pixel to evaluate how users interact with the site. |
|
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Woopra |
We use Woopra to evaluate how users interact with the site. |
|
|
Intercom |
We use Intercom to manage our interactions with customers.
|
|
|
Getsitecontrol |
We use Getsitecontrol to place forms and pop-ups on the site for engaging with the audience. |
|
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First Promoter |
We use First Promoter for affiliate and referral programs. |
How long are cookies stored on your device?
The company uses the information contained in cookies only for the purposes mentioned above. The collected data will be stored on your device for a period that may depend on the specific type of cookies but does not exceed the time necessary to achieve their purpose, after which they will be automatically deleted from your system.
How to control cookies?
You can control and manage cookies in various ways. Remember that deleting or blocking cookies may adversely affect your user experience, and some parts of our platform may no longer be fully accessible.
Most browsers automatically accept cookies, but you can choose whether to accept cookies or not using the controls in your browser, often found in the 'Tools' or 'Settings' menu of your browser. Additional information on how to change browser settings or how to block, manage, or filter cookies can be found in your browser's help file or on sites like allaboutcookies.org.
Many of the third-party advertising and other tracking services listed above offer you the ability to opt-out of their tracking systems. You can learn more about the information they collect and how to opt-out by following the links to the privacy policies listed above.