Политика конфиденциальности

KWORK SERVICE
PRIVACY POLICY
EFFECTIVE DATE – MAY 25, 2018

We are Mirafox Limited, a company registered under No. 2386193, with its address at: of Unit F, 11/F, CNT Tower, 338 Hennessy Road, Wan Chai, Hong Kong and Kwork Technologies OU, a company registered under No. 14531126, with its address at: Harju maakond, Таllinn, Kesklinna linnaosa, Nаrvа mnt 7,634, Estonia.

"KWORK Service" means an online interactive service jointly managed by Mirafox Limited and Kwork Technologies OU, available via URL https://kwork.com.

All references to "we," "us," or "our" shall be construed to mean Mirafox Limited, Kwork Technologies OU and KWORK Service.

The terms "Controller" and "Processor"

Controller - The KWORK Service that processes the personal data you provide to us as a Service User when contacting us through the "Contact Us"/"Support Service" form, during registration, or when using other data transfer methods.

Processor - The KWORK Service that collects the personal data of employees or representatives of Service Users, but which does not process, control, or store this personal data.

When We Act as Controller and Processor

The KWORK Service will act as the Controller of the personal data you provide directly to us via a "Contact Us" / "Support Team" form, when creating an account, or via other contact methods. You are not required to provide your personal information for purposes of navigating through the public areas of our website.

If you are an employee or an authorized representative of one of our clients, who has entered into an agreement with us for the provision of our products or services, we will be act as the Processor of your personal data transmitted by our client. Our client will act as the Controller of your information. As the Processor, we do not own, control, or use of any data provided to us by our clients who act as Controllers.

Personally Identifiable Information

"Personally Identifiable Information" (or "PII") refers to contact information that directly or indirectly tells specifically who you are, such as your name, phone number, country and city, company name, email address, IP address or any other information that could be linked to you with reasonable effort. We do not collect sensitive information such as GPS information, race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data about an individual's sex life.

Additional Personally Identifiable Information

As "Additional Personally Identifiable Information" (or "APII"), we collect your passport data and selfie images for additional online verification of our clients.
To do this, we use the our online partner, Sum & Substance, available at https://api.sumsub.com/checkus.
(hereinafter referred to as the "Verification Service").

Passively or Automatically Collected Data

Passively or automatically collected data (referred to as "Usage Data") is collected as you use this website. We, our affiliated entities, and our marketing partners may use automated means to collect various types of information about you, your computer or other device used to access this website, its services, related web applications, and downloadable software. This information is based on your usage of this website and may be based on your visitation to other websites. Usage Data is essentially anonymous when collected, but could be used indirectly to identify a person.

Why We Need Your Data

We need to know the PII you provide to us directly in our capacity as Controller in order to respond to your inquiry on our Contacts web page and other contact methods. In addition, we need to know your PII to send you emails for other specific purposes and for sharing your PII for the purposes described in the "Information Sharing and Disclosure" section below. We also need to know the PII of the authorized representatives of our clients when we act in our capacity as Processor for purposes of managing the authorized use of our services.
We need to know your APII, so we can fully identify and verify our authorized users in order to eliminate dishonest actions and fraud, and to increase users' confidence in the Service.

How We Collect and Use Your Data

The KWORK Service collects PII directly from you when you send us a message, indicating your email address in the "Contact us"/"Support Team" form on our web pages, or other contact methods, and when you register on the website.

When you register with the KWORK Service, you consent to the collection of your PII, you agree that we will send you emails, and you agree to our use of your PII for marketing emails to promote our products or products similar to our products or services. You may withdraw your consent at any time by unsubscribing to our emails by using an opt-out link contained in every email.

The KWORK Service uses third-party applications to add firmographic information to the data we collect from you. This data enhancement allows us to provide more helpful, personalized communication.

We collect Usage Data as described above and with cookies. For additional information and how to set your browser to refuse to accept cookies, see the "Cookies and Opt-Out Procedures" section below.

We may make full, unrestricted use of Usage Data for any purpose at our sole discretion, including without limitation, to customize re-marketing ads (except for the European Union), offers and content made available to you based on your visits to and/or usage of this website or its services, and to analyze the performance of those ads, offers and content, as well as your interaction with them.

Subject to your right to opt-out, we may combine Usage Data with PII that we collect, and use the combined data to create profiles about you only for purposes of improving our products and services and your user experience with our products and services.

We will not retain your PII for longer than required. This means that we will keep your PII for any or a combination of the time periods described as follows:

for as long as required by law,
until we no longer have a valid reason for keeping it,
until you request us to stop using it,
or for as long as the client of which you are an authorized representative remains our client.

When we delete your PII from our databases, it will remain in our backup system until it cycles out.
For the collection of APII, the KWORK Service involves its Authorized Partner — Verification Service.
The Verification Service directly collects, processes, and stores the APII received during the verification process, in compliance with all rules of the current legislation of Russia and the European Union.
The KWORK Service is not involved in the process of collecting and processing APII, and does not store or use this information. It receives all the necessary verification data from the Verification Service.

How Long We Keep Your Data

We will not retain your PII for longer than required. This means that we will keep your PII for any or a combination of time periods described as follows:

for as long as required by law,
until we no longer have a valid reason for keeping it,
until you request us to stop using it,
or as so long as the client of which you are an authorized representative remains our client.

When we delete your PII from our databases, it will remain in our backup system until it cycles out.

The Verification Service stores your APII in full compliance with the aforementioned rules of this section.

Information Sharing and Disclosure

General Disclosure Policy. We may share and disclose your PII as described below. We may share and disclose Usage Data without restriction, including without limitation, as described below. Please contact us at support@kwork.com to opt out of all information sharing with a third party

Affiliated Entities. We may provide your PII and Usage Data to any affiliated entities we may have, including our subsidiaries. Affiliated entities are entities that we legally control or that control us.

Sub-Processors. We may provide access to your PII and Usage Data to our trusted sub-processors that assist us with the operation and maintenance of this website. For example, we may contract with third parties to process payments, host our servers, provide security, and provide production, fulfillment, optimization, analytics, reporting, and software maintenance and development services. In addition, our sub-processors will be given access to your information only as is reasonably necessary to provide the services for which they are contracted.

Successors. If we sell or otherwise transfer part or all of our business or assets to another organization, such as in the course of an acquisition, merger, bankruptcy or liquidation, we may transfer your PII and Usage Data. In such an event, we will require the buyer or transferee to agree to our commitments provided in this Privacy Policy.

Compelling Obligations. Except for sharing your information as described in this "Information Sharing and Disclosure" section, the KWORK Service will not disclose information about you or the contents of your communications unless compelled to do so in the good-faith belief that such action is reasonably necessary:

(a) to comply with the law;
(b) to comply with legal process;
(c) to enforce these terms and conditions;
(d) to respond to claims that any content violates the rights of third parties;
(e) to facilitate the terms of acquisition of the KWORK Service by, or merger with, another company,
or (f) to protect the KWORK Service’s interests regarding its property, including without limitation its intellectual property.

Authorized Resellers. We may share your PII and Usage Data with our authorized resellers and partners so that they can provide clients with timely, helpful information about our products and services. Our resellers are contractually obligated to abide by the KWORK Service Privacy Policy, preventing them from sharing your information with any other third parties.

Marketing Partners for Purposes of Re-Marketing. We may share your information with third-party vendors for purposes of re-marketing. For a description of re-marketing and your rights to opt-out, see the "Remarketing" section below.

Cookies and Opt-Out Procedures

The KWORK Service may automatically collect Usage Data through the use of "cookies". Cookies are small text files a website uses to recognize repeat users, facilitate the user’s ongoing access to the website, and facilitate the use of the website. Cookies also allow a website to track usage behavior and compile website-usage information that will allow for the improvement of content.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting, you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our website.

Remarketing

The KWORK Service uses third-party vendor remarketing tracking cookies and pixels, including the Google Adwords tracking cookie and the Google Tag Manager tracking code.

This means we will continue to show ads to you across the internet, specifically on the Google and Yandex Content Network, Facebook Ads and through the MyTarget remarketing network. The third-party vendors, including Google, will place cookies in web browsers in order to serve ads based on past visits to our website. This allows us to make special offers and continue to market our products to those who have shown interest in them. We do not remarket to users in the European Union.

You may opt-out of Google’s use of cookies by visiting the Ads Preferences Manager. You may disable remarketing in Yandex on the Ad Settings page. You may opt-out of Facebook Ads on your Facebook account. You may opt-out of MyTarget Ads on the MyTarget Privacy web page. Also, you can opt out of other third-party use of cookies by visiting the Network Advertising Initiative opt-out page.

Analytics

We may participate with third-party analytics partners to monitor and analyze web traffic and to track user behavior on this website.

Google Analytics (Google). Google Analytics is a web analytics service provided by Google Inc. ("Google"). Google utilizes the data collected to track and examine the use of this website, to prepare reports on its activities, and to share them with other Google services.
Information collected: Сookie and Usage Data. Visit the Privacy Policy at https://policies.google.com/?hl=en. You may opt-out of the Google Analytics service with the Google's Browser Add-on available at https://tools.google.com/dlpage/gaoptout.

LiveInternet Analytics (LiveInternet) is a web analytics service, used most in Russia and Russian-speaking countries. It uses the data collected to prepare reports on the activities of this website.
Information collected: Сookie and Usage Data. You may opt-out of the Liveinternet service by sending a request from the Contacts page.

Yandex Metrika (Yandex) is a web analytics service provided by Yandex N.V. ("Yandex"). Yandex utilizes the data collected to track and examine the use of this website, to prepare reports on its activities, and to share them with other Yandex services.
Information collected: Сookie and Usage Data. Visit the Privacy Policy at https://yandex.ru/legal/confidential/. You may opt-out of the Yandex Metrika service by installing a Blocker from Yandex Metrika.

Your Rights

You may contact us to find out if we are processing your PII. If we are, you can ask us what Personally Identifiable Information of yours we store and what we do with your data. If you would like, we can also provide you (or, where technically feasible, your chosen third party) with a copy of any PII about you that we store, subject to a fee specified by law (not to exceed the reproduction cost of these documents).
We may decline a request for access to or correction of PII in circumstances prescribed by law, and if we do, we will provide you with a written notice that sets out the reasons for the refusal.

In addition, you may:

request access to and rectification or erasure of your PII,
request limited processing of your PII,
and withdraw your consent at any time.

If you provide notice to us regarding your exercise of any of the above rights, we will forward your notice to other authorized parties which are storing and processing your PII, where appropriate.

Privacy Complaints Notice for Users in the European Union

Mirafox Limited is committed to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Policy should first contact Mirafox Limited at support@kwork.com.

You may refer unresolved personal privacy complaints to the EU Data Protection Authorities. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Mirafox Limited will cooperate with the appropriate EU Data Protection Authorities during investigation and resolution of complaints brought.
As a last resort, complaints regarding a violation of personal privacy that remain unresolved after pursuing these and other channels are subject to mandatory internal arbitration until the European Commission establishes a special Personal Data Protection Commission.

International Transfers

Your PII and Usage Data are sent to the Netherlands, where our servers are located. That information may be then transferred within the Netherlands or back out of the Netherlands to other countries outside of your country of residence. These countries may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage, and use of your PII and Usage Data will at all times be governed by this Privacy Policy.
APII is not involved in international data transfers in accordance with this Policy.

Links to Other Websites

This website may contain links to other websites. If you do click on any of the links to their websites or accept any of their promotional offers, your click-through information and any information that you provide in the process of registration or purchase will be transferred to these websites. We have no responsibility or liability for the policies and practices of these websites. You should be careful to review any personal data protection policies posted on any of these websites before providing information to them.

Children’s Online Policy

We are committed to preserving online personal data privacy for all of our website visitors, including children. This website is a general audience website. Consistent with the Children's Online Privacy Protection Act (COPPA), we will not knowingly collect any information from, or sell to, children under the age of 13. If you are a parent or guardian who has discovered that your child under the age of 13 has submitted his or her personally identifiable information without your permission or consent, we will remove the information from our active list, at your request. To request the removal of your child's information, please contact our website as provided below under "Support Team", and be sure to include in your message the same login information that your child submitted.

Do-Not-Track Requests

Some Web browsers incorporate a "Do Not Track" feature that signals to websites that you visit that you do not want to have your online activity tracked. Each browser communicates "Do Not Track" signals to websites differently, making it unworkable to honor every request correctly. In order to alleviate any communication error between browsers and a website, we do not respond to "Do Not Track" signals at this time. As the technology and communication between browser and website improve, we will reevaluate the ability to honor "Do Not Track" signals and may make changes to our policy.

Inquiries and Complaints

If you have any inquiries or complaints about our use of your PII, please let us know. You can contact us at any time via the "Support Team" section below, and we will take reasonable steps to investigate the complaint and respond to you.

Contact Us

Contact us, as follows.
Mirafox Limited
Unit F, 11/F, CNT Tower, 338
Hennessy Road, Wan Chai, Hong Kong
support@kwork.com

Modifications of materials since March 13, 2017: updates effective May 25, 2018 for purposes of compliance with the EU General Data Protection Regulation (GDPR).

KWORK TECHNOLOGIES OÜ
Registry code: 14531126
IBAN: GB89 EPMT 0099 7226 8060 77
BIC (SWIFT): EPMTGB2L
+79275595558

List of Data Subprocessors

Current as of: November 25, 2019
The following is the KWORK Service’s current list of Subprocessors authorized to process client data for the KWORK Service.

Subprocessor	Type of Processing
Serverel	Hosting Provider
Paymore.org	Payment Processing
Solar Staff	Payment Processing
Bitrix24	CRM

If you have any questions, please contact us at support@kwork.com.