PRIVACY POLICY

Publication date: July 1, 2023

Welcome to Clicknsub - a Platform created to provide the Customer with the ability to obtain functions for their Bot.

The Privacy Policy regulates the procedure for ensuring the security of Personal data when using Clicknsub Services.

In this document, we describe the methods of collecting, processing, storing, disclosing and transferring Personal data when using Clicknsub Services.

The provisions of this Privacy Policy apply only to Personal data obtained by the Platform in the ways described in its terms.

References to the words "you" or "your" (or similar words) mean the Customer or Subscriber depending on the context of the Privacy Policy.

References to the words "Platform", "we", "our" or "us" (or similar words) mean the Clicknsub Platform.

The words he/she and their derivatives in the text of the document may apply to both male and female persons, depending on the context of the document.

DEFINITIONS
1. Customer - any natural person, individual entrepreneur or legal entity that receives Services from the Platform.
2. Subscriber - any natural person, individual entrepreneur or legal entity that interacts with the Customer by using the functions of the Customer's Bot and may receive from the Customer certain services/products/goods/information, etc.
3. Project - a set of settings that the Customer chooses in the Clicknsub Telegram Bot when receiving Services.
4. Representative - any natural person who has the right to act on behalf of the Customer on legal grounds, including representing the Customer to receive Services.
5. Customer Consent (hereinafter "Consent") - voluntary, specific, informed and unambiguous expression of will in which the Customer agrees to the processing of their Personal and Statistical data through a statement or clear positive action.
6. Personal data - any information that is in closed access that allows direct or indirect identification of the Customer. For example, name, surname, phone number, IP address.
7. Statistical data - any information that is in open access and directly or indirectly belongs to the Customer. For example, data about the name or address of the Customer's company.
8. Platform "Clicknsub" (hereinafter "Platform" or "Clicknsub") - a service created to provide the Customer with the ability to add their Bot and manage its settings, including obtaining functions through the Platform.
9. Landing-bot (hereinafter "Bot") - a bot in the Telegram messenger that was created by the Customer and added by the Customer to Clicknsub for the purpose of receiving Services and interacting with Subscribers.
10. Website of the "Clicknsub" Platform (hereinafter "Website") - means a web page or group of web pages on the Internet located at: https://www.clicknsub.com/, through which the Platform provides Services to Customers.
11. Telegram Bot Clicknsub - a bot in the Telegram messenger that belongs to the Platform and through which Services are provided to the Customer.
12. Services - an algorithm of actions performed by the Platform to provide the Customer's Bot with access to functions by using the Clicknsub Telegram Bot, for the corresponding fee indicated on the Website. The terms of providing Services are regulated by the Public Offer posted on the website at https://www.clicknsub.com/uk/page/terms.
13. Public Offer (hereinafter "Agreement") - a public offer concluded by the Platform with any Customer in electronic-digital form on the Website, by using the checkbox function.
14. Appendix - a legal document in written form that is an integral part of the Public Offer, and in which the parties specify the terms of providing Services by the Platform to the Customer.
15. Third party - means a natural or legal person, state institution, institution or body, different from the Customer and the Platform.
16. Cookie - a piece of information in the form of text or binary data used by the Platform when you use the Website to obtain additional information about you.
BASIC PROVISIONS
1. The Platform processes and stores Personal data based on the principles of legality, fairness and transparency in accordance with the Law of Ukraine "On Personal Data Protection" (original link https://zakon.rada.gov.ua/laws/show/2297-17#Text).
2. The Platform is not responsible for the processing of Personal and Statistical data by any Third parties that are not controlled by or do not belong to Clicknsub.
PERSONAL AND STATISTICAL DATA
1. The Platform may receive the following Personal data about the Customer (natural person):
  1. full name;
  2. contact phone;
  3. identifier in Telegram messenger;
  4. e-mail.
2. The Platform may receive the following Personal data about the Representative of the Customer (legal entity):
  1. full name;
  2. contact phone;
  3. identifier in Telegram messenger;
  4. e-mail.
3. The Platform may receive the following Statistical data about the Customer:
  1. company data: name, legal address, form of business activity, country of registration and activity, IBAN, field of activity, data about employees and management, etc.;
  2. registration/tax number/EDRPOU/RNOKPP;
  3. contact data: phone number, email, etc.;
  4. payment/banking details, exclusively for receiving payment for Services;
  5. data about the field of activity, including data about services/products/goods/information provided by the Customer to the Subscriber;
  6. identifier in Telegram messenger;
  7. data about employees that are in open access.
4. The Platform informs that payment data of Subscribers (bank card number, date and CVV code, etc.) are processed exclusively by the payment service and/or bank that provide services for processing payment for Customer services.
5. The Platform informs that it may process Personal data and Statistical data of Representatives and employees of the Customer, and such data will be processed in accordance with this Privacy Policy.
6. The Platform may collect Personal and Statistical data during communication with the Customer, obtained through social networks, messengers, email. In such case, such data will be processed in accordance with this Privacy Policy.
7. Clicknsub does not collect or process sensitive Personal data of the Customer, such as racial or ethnic origin, political views, religious or philosophical beliefs, trade union membership, genetic or biometric data, health information, sexual life or sexual orientation.
8. When providing Services, the Platform may receive data about the Customer's communication language and such data will be processed in accordance with this Privacy Policy.
9. The Platform informs that the Platform has access to Subscriber data that they publish in the Customer's Bot, but the Platform does not store Subscriber data in any way, except for the identifier in the Telegram messenger. Such data is stored and processed exclusively by the Customer through their Bot. The Customer is obliged to inform the Subscriber that their data may be processed by the Platform and the Customer bears sole responsibility for such notification.
10. The Platform informs that it may receive Customer data from the payment system used by the parties for mutual settlements, including but not limited to: merchant ID in the payment system.
11. The Platform informs Customers that their data and their clients' data are collected through the system when providing Services.
12. When using the Website or receiving Services, the Platform may automatically collect the following Personal and Statistical data of the Customer:
  1. IP address;
  2. time zone and language settings;
  3. operating system, device type and screen resolution;
  4. country where you are located;
  5. data about your visit to the Website, including complete URL information, route of transitions to the Website and when moving to/from the Website (including date and time), page response time, data loading errors, duration of stay on certain pages, page activity (such information as scrolling and mouse movements, clicks), methods used to exit the page and phone numbers used to contact the customer service center.
13. The Platform has the right to collect and receive Personal and Statistical data in the following ways:
  1. when providing Services;
  2. during Bot creation by Platform employees;
  3. during Project creation;
  4. when filling out the Appendix;
  5. when using the Website;
  6. when interacting with Platform employees through exchange of emails/messages, communication with Platform employees;
  7. during monitoring and evaluation of Customer actions to detect and prevent fraud;
  8. use of log files, Cookie files and other tracking technologies;
  9. through messengers and social networks.
14. The Platform has the right to use Personal and Statistical data for the following purposes:
  1. providing Services;
  2. to ensure Website security;
  3. for Website administration and conducting internal operations, including troubleshooting, data analysis, testing and filling out surveys;
  4. to improve Website navigation;
  5. communication with the Customer;
  6. responding to law enforcement requests;
  7. to initiate responses to legal claims, investigations or dispute resolution with you.
TRANSFER OF PERSONAL/STATISTICAL DATA
1. The Platform may transfer Personal or Statistical data to entities with which the Platform cooperates in the implementation and provision of Services:
  1. Payment service/Bank. To receive payment for Services, Personal and Statistical data may be transferred to the payment service/bank.
  2. Contractors and employees. The Platform may transfer your Personal and Statistical data to other persons with whom it begins cooperation, including legal and tax consultants, as well as persons who provide accounting, logistics, marketing and IT services.
  3. Counterparties. The Platform has the right to disclose or transfer Personal and Statistical data in the following agreements: acquisition or merger, financing, corporate reorganization, joint venture, including sale of assets or bankruptcy.
  4. Courts, law enforcement agencies and government bodies. The Platform has the right to transfer Personal and Statistical data in case of fulfilling any legal obligations, including by court decision.
CUSTOMER CONSENT
1. One of the following actions by the Customer means Consent to the terms of this Privacy Policy:
  1. creation of a Bot by Platform employees and transfer of rights to such Bot to the Customer in Telegram messenger;
  2. placing it on the Platform;
  3. receiving Services.
2. By agreeing to the terms of this Privacy Policy, the Customer gives their Consent to:
  1. use and processing of their Personal and Statistical data, in accordance with the terms of the Privacy Policy;
  2. providing the Platform with additional information and Personal and Statistical data at the Platform's request;
  3. processing of their payment details by the payment service/bank in accordance with the terms of this Privacy Policy;
  4. transfer of their data to third-party services, in accordance with the terms of this Privacy Policy;
  5. providing information about their services/products/goods/field of activity.
3. The Platform reserves the right to obtain Customer Consent through a pop-up form. The pop-up form may contain a Consent form in the form of a checkbox.
STORAGE AND PROTECTION OF PERSONAL/STATISTICAL DATA
1. The Platform uses basic measures to protect Personal and Statistical data. Data is stored in a database with limited access and administrator authorization system.
2. The Platform protects and stores Personal and Statistical data from:
  1. loss - by creating regular backups;
  2. illegal use, transfer, disclosure, modification, deletion and/or destruction - through a system of access rights differentiation, application of reliable passwords for the database, use of virtual private network for server access and other organizational and technical security measures.
3. The Platform has the right to store Personal and Statistical data of the Customer for 3 (three) years after termination of relations in the following cases:
  1. for statistical accounting;
  2. if current legislation requires their storage;
  3. if they are necessary for conducting business;
  4. for marketing analytics.
GROUNDS FOR PROCESSING PERSONAL/STATISTICAL DATA
1. The Platform processes Personal and Statistical data on the following legal grounds:
  1. Customer Consent;
  2. receiving Services from the Platform;
  3. creation of a Bot by Platform employees and transfer of rights to such Bot to the Customer in Telegram messenger.
2. In cases where the basis for processing Personal and Statistical data is your Consent, you have the right to withdraw it at any time. To withdraw your consent, you can send an email to: . In case of withdrawal of your Consent, the Platform has the right to stop providing Services and terminate all relations with you. If Consent is withdrawn, your Personal and Statistical data will be irreversibly deleted.
3. The Platform undertakes to stop processing Personal and Statistical data within 15 (fifteen) business days from the moment of receiving the withdrawal of Consent.
CUSTOMER RIGHTS
1. The terms of this section apply to Customers and relate to specific requirements, in accordance with the provisions of Ukrainian legislation, in particular the Law of Ukraine "On Personal Data Protection":
  1. to receive information about the conditions for providing access to Personal data, in particular information about Third parties to whom they are transferred;
  2. to receive information, no later than thirty calendar days from the date of receipt of the request, except for cases provided by law, a response about whether Personal data is being processed;
  3. to send a reasoned demand regarding objection to Personal data processing;
  4. to send a reasoned demand regarding modification or deletion of Personal data;
  5. to protection of Personal data from illegal processing and accidental loss, destruction, damage due to deliberate concealment, non-provision or untimely provision, as well as protection from providing information that is false or defames the honor, dignity and business reputation of the Customer;
  6. to appeal to the court with complaints about Personal data processing;
  7. to apply legal remedies in case of violation of personal data protection legislation;
  8. to make reservations regarding restriction of the right to Personal data processing when giving consent;
  9. to withdraw consent to Personal data processing;
  10. to know the mechanism of automatic Personal data processing;
  11. to protection from automated decision that has legal consequences for them.
SUBMITTING A REQUEST
1. The Customer has the right to submit a request to the Platform if they believe that their rights have been violated by writing a request in written form to Platform support at: .
2. The Customer's request must contain reliable information regarding requirements to the Platform. If the request does not specify exact requirements, the Platform 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 and Statistical data if we cannot confirm your identity and confirm that the Personal and Statistical data belongs to you. In case of receiving a request with unreliable information and/or in case of inability to confirm the Customer's identity, the Platform has the right not to process the received request and contact the Customer for clarification. In case of receiving a response to the clarification request, the Customer must provide a new corrected request or submit a new request.
4. The Platform is obliged to respond to the request or fulfill the conditions set out in the request within 15 (fifteen) business days from the moment of its receipt.
RESPONSIBILITY
1. The Platform informs the Customer that Personal and Statistical data may be used to provide Services, and in case of disagreement with this, the Customer has no right to receive Services.
2. The Platform is not responsible in case the Customer provides unreliable Personal and Statistical data, including the inability of the Customer to receive Services.
3. The Platform is not responsible for any damages caused to the Customer as a result of using their Personal and Statistical data by a Third party without their knowledge, including third-party services (partners, payment systems, web analytics services, etc.), since their Personal and Statistical data is processed in accordance with the privacy policies of such services.
4. The Platform deliberately does not check content and data published by the Customer on Bot pages, including information and content published by Subscribers of this Customer. The Platform may stop providing Services to the Customer and restrict access to Bot functions if this Customer's Bot contains the following content/information:
  1. in any way violates the rights of a Third party, including property and/or intellectual rights;
  2. contains illegal information;
  3. contains false or incorrect information;
  4. contains signs of pornographic or sexual nature, profanity;
  5. humiliates the honor and dignity of a Third party, other Customers/Subscribers/Third parties;
  6. incites interracial, international, religious, gender and political hatred;
  7. violates the rights and/or freedoms of other Customers/Subscribers/Third parties;
  8. contains links to third-party websites that may harm the software of other Customers/Subscribers/Third parties;
  9. contains links to sites that distribute pornography, unlicensed software and/or media files or incite interracial, ethnic, religious, sexual and political hatred;
  10. contains links to information that is open advertising platforms for network marketing, affiliate marketing, financial pyramids, work from home and other types of fraud;
  11. contains profanity;
  12. contains jargon in the amount of more than 30 (thirty) percent content;
  13. contains flood;
  14. contains various ways to attract potential clients, such as get rich quick, financial independence, etc.;
  15. contains offers for credit restructuring and debt relief;
  16. contains advertising of alcoholic and/or tobacco products;
  17. contains spam;
  18. contains calls for violence;
  19. contains slander;
  20. uses multiple grouped punctuation marks;
  21. contains links to sites that are dating services, escort, etc.;
  22. contains signs of begging;
  23. contains links to websites and/or information about personal growth courses, career development, etc.
5. The list of requirements specified in paragraph 10.4. of this section of this Privacy Policy is not exhaustive, and the Platform has the right at its discretion to stop providing Services if the Platform has grounds to believe that posting such content may harm a Third party, the Platform's business reputation or violates current legislation of Ukraine.
6. The Platform informs the Customer that they personally bear responsibility for processing/storing personal and statistical data of the Subscriber, including compensating the Subscriber for any damages caused by disclosure of their personal and statistical data.
7. The Customer undertakes to:
  1. obtain consent from the Subscriber for processing their personal and statistical data;
  2. ensure storage of the Subscriber's personal and statistical data;
  3. compensate all damages to the Subscriber in case of disclosure of their personal and statistical data;
  4. ensure legal resolution of disputes and court proceedings arising from disclosure of Subscribers' personal and statistical data, including protection of rights and interests of the Platform and its affiliated persons;
  5. process Subscribers' data in accordance with Ukrainian legislation.
8. The Platform may refer to other websites or services. The Privacy Policy of these websites and services is not governed by the terms of this Privacy Policy, and the Platform cannot be responsible for processing the Customer's Personal and Statistical data by third-party websites and services.
9. The Platform is not responsible for:
  1. loss of Personal and Statistical data in case of hacker attack, hacking of Platform or Website software, illegal actions of Third parties, as well as actions that violate the terms of the Privacy Policy;
  2. inability to provide Services or poor quality provision of Services in case the Customer provides unreliable Personal and Statistical data or any other information;
  3. any failures and malfunctions in Bot operation that arose not through the Platform's fault;
  4. Customer's use of the Bot for illegal purposes;
  5. posting illegal content on Bot pages;
  6. provision of false information by the Customer.
10. Unfortunately, transmission of information over the Internet cannot be completely secure. Although we make every effort to protect Personal data, we cannot guarantee a secure process of transmitting Personal and Statistical data to the Website. In this regard, you bear sole responsibility for possible failures in transmitting your Personal data to the Platform.
COOKIE FILES
1. Cookie files do not transmit viruses and/or malicious software to your device, since data in Cookie files does not change during transmission and does not affect the performance of your device in any way. They are more like logs (i.e., record Customer actions and remember information about state) and are updated every time you visit the Website.
2. When providing Services, we may use the following types of Cookies:
  1. Session Cookie files, also known as temporary Cookie files, exist only in temporary memory while the Customer is on the Website page. Browsers usually delete session Cookies after the Customer closes the browser window.
  2. Persistent Cookie files are deleted on a certain day or after a certain period of time. This means that Cookie file information will be transmitted to the server every time the Customer visits the website to which these Cookie files belong.
  3. Third-party Cookie files are a type of files that appear when a web page contains compressed content from external websites, for example links to other websites. For example, they may be used to track the Customer's visit history to other websites.
  4. Web analytics Cookie files are used to analyze Customer behavior when viewing different Website pages.
3. The Platform uses Cookie files for the following purposes:
  1. authentication and identification;
  2. conducting web analytics;
  3. marketing analytics research;
  4. research of Customer preferences;
  5. storing personal preferences and settings;
  6. tracking access sessions;
  7. storing statistical data;
  8. Website analysis.
4. In many cases, web browsers by default allow storing Cookie files on the Customer's end device. Website customers can change Cookie file settings at any time to block automatic processing of Cookie files or notify about each placement on the website Customer's device. Detailed information about possibilities and methods of processing Cookie files is available in your browser settings.
ADULT POLICY
1. Platform Services are intended for persons who have reached the age of eighteen. The Platform does not process Personal and/or Statistical data of persons who have not reached such age.
2. The Platform has the right to delete Personal and Statistical data of a person who has not reached the age of eighteen, without warning and any consequences for the Platform, as well as to stop providing Services to such person.
3. If you have information about receiving Services by a person who has not reached the age of eighteen, contact Platform support by sending an email to: .
PRIVACY POLICY CHANGES
1. We have the right to periodically make changes to the Privacy Policy for the security of Personal and Statistical data, and compliance with Ukrainian legislation requirements.
2. The Customer must familiarize themselves with the new terms of the Privacy Policy and the Platform is not responsible if the Customer has not familiarized themselves with the new terms of the Privacy Policy.
3. The Platform updates the change date of the current version of the Privacy Policy in the "Updated" line at the top of the document.
4. Our electronic copies of the Privacy Policy are considered true, complete, valid, legally binding and effective at the time of your visit to the Website.
CONTACTS

The Customer has the right to contact Platform support at: to ensure their rights, in accordance with the terms of this Privacy Policy, or in case of violation of their rights, or to leave feedback or ask questions.

PRIVACY POLICY

DEFINITIONS

BASIC PROVISIONS

PERSONAL AND STATISTICAL DATA

TRANSFER OF PERSONAL/STATISTICAL DATA

CUSTOMER CONSENT

STORAGE AND PROTECTION OF PERSONAL/STATISTICAL DATA

GROUNDS FOR PROCESSING PERSONAL/STATISTICAL DATA

CUSTOMER RIGHTS

SUBMITTING A REQUEST

RESPONSIBILITY

COOKIE FILES

ADULT POLICY

PRIVACY POLICY CHANGES

CONTACTS