Last updated: April 1, 2020.

 

Your privacy is of essential importance to us. We have a few fundamental principles:

  • We are thoughtful about the personal data we ask you to provide and the personal information that we collect about you through the operation of our services.
  • We store personal information for no longer we really have a need to keep it or when it is required by law.
  • We aim to make it as simple as possible for you to control what information on this website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
  • We aim for full transparency on how we gather, use, and share your personal information.

Below is our Privacy Policy, which incorporates and clarifies these principles.

Who We Are and What This Privacy Policy Covers

Hi there! We are the folks behind this website. We are Anoeses, registered in Ukraine.

This Privacy Policy applies to information that we collect about you when you use:

  • Our website – anoeses.com;

Throughout this Privacy Policy we’ll refer to our website.

We are committed to protect and respect your privacy. This Privacy Policy sets out how we may use, process and store your personal information. If such personal information can directly or indirectly refer to you as a natural person, such information consists your “Personal Data” and shall be protected by us with a strict accuracy. Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

If you have any questions about this Privacy Policy, please contact us.

How We Can Receive Your Information

We may get that information from you or our partners, through contracts or other legal arrangements you have with us or our partners on behalf of us, in order to deliver contractual/legal obligations. Your permission and consent can be collected by us directly, or we may receive your personal information from third parties whom you have given consent to pass this information on to us.

Information we collect about you

If you visit our website or member communities, we may automatically collect information about you, for example:

  • Technical information
  • IP addresses
  • Information about what type of device you use to connect to our website
  • How you interact with our website.

For more information read our Coolie Policy

Here you can find the types of the Personal Data we collect and the purposes of its processing.

#

Information types

Purpose of collecting

1

User’s Country

verification of the User

prevention of fraudulent use and resale of User’s accounts

tax implications, VAT purposes

2

User’s email

the main contact of communication with User

to provide you with marketing and promotional materials

3 User’s phone number

 the main contact of communication with User

 to provide you with marketing and promotional materials

4

User’s Name and Surname

verification of the User

for invoices, billing and taxation

prevention of fraudulent use and resale of User’s accounts

5

City/state/ZIP code/address

billing information for invoices


Why do we collect Personal Data?

We collect information for the some or all of following reasons:

  • To provide services to you after you have ordered one of our services through the website;
  • To provide information about products you have shown interest in purchasing within a reasonable time afterwards, if you are already an existing customer;
  • To provide information to you about products you have purchased from us, or related products;
  • For legal reasons, for example, if you have entered into a contract with us;
  • To provide information to you about our products if you have consented to receive it.

Grounds of collecting information from you

We may collect information from you when we have a legal reason to collect the information, or when you have consented for us to do so for a specific purpose (e.g. services provision or newsletters).

Legal basis we have for processing your personal data

  • We may process your personal data because:
  • You have given us permission to do so;
  • We must provide products to you because you have ordered them;
  • You have asked us to do so;
  • To comply with the law.

All of these reasons are reasons we may legally process the information we have about you.

Ways of giving information

You may give us information about you with your consent, for example:

  • By filling in a form or sending us an e-mail;
  • By posting an order at the website;
  • Posting reviews and feedbacks at the website;
  • Contacting with us through our phone numbers.

This information may be personal, financial, educational, or related to your order.

You may give us information for legal reasons, such as to enter into a contract with us, when you are buying services from us.

Information we receive from other sources

We may receive information about you from third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them as part of the service we provide you, or for other legal reasons.

Files. We may collect and store the files you upload, download, or access with the website or in the personal communication. Please do not share with us the files you are not permitted to use. Please do not upload or share with us the files that contain your personal information or personal information of third parties without permission. We may not guarantee that such personal information will be secured.

Who might we share your information with?

We may share your personal data with third parties, either because you have consented to allow us to do so or for other legal reasons. For example, we may share your personal information with:

  • Our marketing staff to provide you with promotional materials;
  • With third parties because you have given consent;
  • With third parties who provide us services because you have purchased goods or services.

Other reasons we may share your personal information with a third party

If Anoeses or substantially all its assets are acquired by a third party, personal data held by it about its customers will be one of the transferred assets of the company.

In addition, we will share your personal data with third parties for the following reasons:

  • If we must comply with a legal obligation;
  • If it is legally requested by government agency;
  • To enforce or apply our Website Terms of Use or other agreements;
  • To protect the rights, property, or safety of Anoeses, our customers or others;
  • If exchange information with third parties aimed to prevent fraud or to reduce our credit risks.

Where we store and process your personal data

We primarily store and process your personal data in the EU/European Economic Area or USA. If you are from EU, by accepting this Privacy Policy, you give us the right to store your personal data in EEA and USA. We assure you that all your data is encrypted in secure way and no unauthorized persons may access them.

Some examples of reasons your data may be processed outside of the EEA include:

  • Order fulfilment;
  • Payment processing;
  • Technical support services.

If your personal data cannot be processed within the EEA, we will:

  • Comply with all data protection principles;
  • Where possible, choose a country that is on the list of the EU Commissions’ countries that provide adequate protection for the rights and freedoms of data subjects;
  • If the transfer is to the United States of America, we will use reasonable endeavors to make sure they participate in the Privacy Shield program;
  • Make sure we have assessed the adequacy of protections in all other cases.

Transmission and storage of your personal data

Unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your data as it is transmitted and stored, however we shall use best practice to ensure your data is encrypted to the standard required in the GDPR to protect your personal data.

How long will we keep your personal data?

We will not retain your Personal Data for longer than required.

We will keep your personal information:

  • 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 delete it.

We may keep just enough of your Personal Data to ensure that we comply with your requests not to use your personal information or comply with your right to erasure. For example, we must keep your request to be erased even if it includes your personal data until such time as you are no longer our customer, or for tax purposes etc.

If you have questions about our Data Retention Policy, we can provide you a copy. Please contact: my@anoeses.com

If you chose not to give your personal information to us

If the Personal Data is necessary in order to provide services to you under a contract between you and FrogProg Limited, we will have to refuse entering into that contract or providing the services before you give us your personal information.

Your Rights

We will respect your legal rights to your Personal Data.

Below are the rights that you have under law, and what we do to protect those rights:

Legal right

What we do to protect your rights

The right to be informed

We are publishing this Privacy Policy to keep you informed as to what we do with your personal information. We strive to be transparent about how we use your data. We will also answer all your questions regarding this Policy send to the my@anoeses.com

The right to access

You have the right to access your information. Please contact our Data Protection Officer at my@anoeses.com if you wish to access the personal information we hold about you.

The right to rectification

If the information we hold about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data. Please contact our Data Protection Officer if you need us to rectify your information: my@anoeses.com

The right to erasure

This is sometimes called ‘the right to be forgotten’. If you want us to erase all your personal data and we do not have any legal reason to continue to process and hold it, please contact our Data Protection Officer: my@anoeses.com

The right to restrict processing

You have the right to ask us to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future. If you want us to restrict processing of your data, please contact our Data Protection Office: my@anoeses.com

The right to data portability

We must allow you to obtain and reuse your personal data for your own purposes across services in a safe and secure way without this effecting the usability of your data. Please contact our Data Protection Officer if you want information how to port your data elsewhere: my@anoeses.com. This right only applies to personal data that you have provided to us as the Data Controller. The data must be held by us by consent or for the performance of a contract.

The right to object

You have the right to object to us processing your data even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purposeless statistics. If you wish to object, please contact our Data Protection Officer: my@anoeses.com

The right to withdraw consent

If you have given us your consent to process your data but have changed your mind later, you have the right to withdraw your consent at any time, and we must stop processing your data. If you want to withdraw your consent, please contact our Data Protection Officer: my@anoeses.com

The right to complain to a Supervisory Authority

You have the right to complain to the Office of the Commissioner for Personal Data Protection if you feel that we have not responded to your requests to solve a problem. You can find their contact details here:

Office of the Commissioner for Personal Data Protection
1 Iasonos str., 1082 Nicosia
P.O.Box 23378, 1682 Nicosia
Tel: 
+357 22818456
Fax: +357 22304565
Email: commissioner@dataprotection.gov.cy

 

Links to Other Websites

From time to time, our website may contain links to and from websites of our social and partner networks or advertisers. If you follow a link to any of these websites, please note that these websites may have their own privacy notices and that we do not accept any responsibility or liability for any such notices. Please check these notices, where available, before you submit any personal data to these websites.

Age Limitations

To the extent prohibited by applicable law, we do not allow use of our Services and Websites by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review them to stay informed. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the Website. If you disagree with the changes to this Privacy Policy, you should leave the Website.

The Laws and Regulations

The laws that govern personal data in EU are:

  • The Data Protection Act (1998)
  • REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing General Data Protection Regulation (“GDPR”).

How can you reach us?

This is our registered address, company number and contact information:

Anoeses
03057 Ukraine,
Kyiv,
3 Aleksandra Dovzhenko street,
Copyright Registration Number: #268149

Email: my@anoeses.com
Phone: 
+38 093 569 66 06