Privacy policy

Who are we? The normative basis. Objection

1.1. The “Three Spheres” enterprise (hereinafter referred to as “Three Spheres”, “us” or “ours” in this Policy) is the data controller responsible for your personal data, with an office registered in the city. Chisinau, Republic of Moldova. We provide services in accordance with the Terms of Use. Our contact details can be found in section 13.

1.2. When processing personal data within the organization, the principles set out in international acts apply, such as: "Universal Declaration of Human Rights", "Convention for the Protection of Human Rights and Fundamental Freedoms", "Convention for the Protection of Individuals with regard to Human Rights" automatic processing of personal data "," Directive 95/46 / EC of the European Parliament and of the Council of the European Union on the protection of the rights of individuals with regard to the processing of personal data and on the free movement of such data ", as well as national data , such as: “Constitution of the Republic of Moldova”, “Law on the protection of personal data”, “Law on access to information”, “Requirements for ensuring the security of personal data in relation to their processing in personal information systems, approved by Government Decree no. 1123 of December 14, 2010 ”,“ Regulations regarding the register of personal data Operators, approved by Government Decree no. 296 of May 15, 2012 ”and other legislative acts.

1.3. The main objectives of the policy are the availability, integrity and confidentiality of all information, including personal data processed by the company both manually and automatically. Security is an integral part of the optimal functioning of IT processes within a company. Adherence to this policy is fundamental to adequate IT security. This includes requirements and rules for the protection of information, including personal data, IT systems and processes from natural influences, human and technical errors, as well as from deliberate actions that may cause material or intangible damage or lead to violations of the law. . Given that IT security cannot only be guaranteed by technical systems, this policy also covers organizational, legal and other issues.

What data do we collect about you?

2.1.1 Data provided through direct interaction

Registration and other account information.

When you register to use our Services, we may collect the following information about you:

• When you register on the platform, you will need to send an e-mail address;

• If you sign in with your Google Account: first name, last name, and email address.

• If you register with your Facebook account: We collect your first and last name as they appear on your Facebook account and your Facebook ID. If you have granted Facebook permission through the in-app privacy option (which appears immediately before you register on our platform), we may receive information about your gender, age or email address, depending on your permission;

• If you register using your mobile phone number: we collect your mobile phone number.

Depending on the authentication method selected on our platform or while using our services, you may provide us with the following additional personal data:

• Your name;

• Phone number;

• Your credit card details if you wish to purchase our paid services in accordance with the Terms of Use.

Communication via chat on our platform

When you use chat to communicate with other users, we collect information that you choose to provide to other users through this feature.

Recording phone calls by our customer support staff or other departments

When you call or decide to call one of our customer service or other service representatives, we record the conversation with your explicit consent to improve the customer relationship.

2.1.2 Data that we automatically collect when using our services

When you interact with our platform or use our services, we automatically collect the following information about you:

Device information

We collect information about devices, such as operating system version, unique identifiers. For example, the name of the mobile network you are using. We associate device identifiers with your account on the site.

Location information

Depending on the permissions on your device, we automatically collect and process information about your actual location if you post an ad on our platform. We use a variety of technologies to determine location, including IP address, GPS, Wi-Fi hotspots, and mobile towers. Location data allows you to view ads from nearby users and helps you run your ads.

Customer data and authentication

Technical details, including device IP address, time zone, and operating system. We'll also store your credentials (registration date, last password change date, last successful login date), browser type.

Navigating historical data

We collect information about your activities on our platform, including the web pages from which you accessed our platform, the date and time of each visit, the searches you performed, the banner ads or content you clicked, your interactions with these types of ads, the duration of your visit, and the order in which you view the content of our platform.

Cookies and similar technologies

We use cookies to manage user sessions, to save language preferences and to serve you relevant ads. Cookies are small text files sent by a web server to your device's hard drive. Cookies can be used to collect data and record your visit time, browsing history, preferences, and username. You can set your browser not to store all or some of your cookies or to warn you when websites install or access cookies. If you disable or refuse cookies, please note that our Services / Platform may become partially unavailable or may not work properly. For more information about the cookies we use, see our Cookies Policy.

2.1.3 Data from third parties or from publicly available sources

We receive your personal data from various third parties and from open sources, namely:

1. Technical and usage information from analytics providers such as Google.

2. Contact details about business transactions in ad networks, such as information about transaction data providers and service partners. (for example: commercial data);

3. Data on the use of platform services related to services or transactions. (eg data directly related to advertisements placed on the platform to prevent fraud and to report such cases to relevant organizations).

Why do we process your personal data?

We will use your personal information only when it is permitted by law. Most often, we will use your personal data in the following cases:

- If we have to fulfill an agreement that we are going to conclude or conclude with you;

- If necessary for our legitimate interests to improve the Services and ensure the security and reliability of the Platform;

- If we are obliged to comply with a legal or regulatory obligation;

- If you give us your explicit consent (for example, in the case of audio recordings);

In certain circumstances, we may process your personal data on the basis of your consent. If we do this, we will inform you about the purpose and category of personal data that we process when we ask for your consent.

The following describes how we use your personal data and what legal basis we rely on.

3.1 To provide access and provision of services through our platform

If you log in using your mobile phone number or email address, we will use your first and last name, phone number and / or email address to identify you as a user and to give you access to the platform.

If you sign in using your Facebook account, we will use your first and last name on your Facebook profile and Facebook email address to identify you as a user of our platform and to give you access to the platform.

The above credentials will also be used to provide our Services in accordance with the Terms of Use.

We will use your email address and mobile phone number (via SMS) to provide suggestions and recommendations about our services that may interest you.

We will process the above information for the proper performance of our contract with you and based on our legitimate interest in conducting marketing activities to provide you with Services that may be of interest to you.

3.2 To improve your experience with the platform

I. We use click data:

- To provide you with personalized content, for example, to provide more relevant search results when you use our Services.

- To determine how you use the navigation on the platform and how much time you spend on it, to understand your interests and to improve our Services based on this data. For example, we can: suggest specific content based on the content you've accessed.

- To track the performance of campaigns and report them to our business partners or use them for internal business analysis.

- To prevent a large number of identical ads from being displayed to the same user.

II. We use your location data for the following purposes:

- To collect anonymous and aggregated information about the characteristics and behavior of our users, including for the purpose of business analysis, segmentation and development of anonymous profiles.

- To improve the efficiency of our Services and to personalize the content we send you. For example - using location data, we run ads relevant to your area to improve your shopping experience.

- To measure and monitor your interactions with advertising banners posted on our Platform.

III. Using your registration data, which includes your email address and phone number, we identify the various devices (e.g., personal computers, mobile phones, tablets) through which you access the Platform. This allows us to connect your activities on the platform to different devices and give you the right capabilities, depending on the device you are using.

We process the above information based on our legitimate interests to improve your experience with our platform and to properly fulfill the terms of your contract with you.

3.3 To provide you with a secure and reliable platform

I. We use your phone number, credentials, and unique device identifiers to manage and protect the Platform (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, support, reporting, and data hosting).

II. We analyze chat messages to prevent fraud and improve security by blocking spam or offensive messages that may be sent to you by other users.

We process the above information in order to properly fulfill our contract with you, to improve our services and based on our legitimate interest in preventing fraud.

3.4 To provide you with strong customer support

I. We record your conversations only with customer service representatives or other service providers, subject to your explicit consent;

We process the personal data mentioned above to further analyze your interactions with our customer service or other service representatives (as appropriate) and to improve the quality of our customer service.

You may, at any time, revoke your consent by sending us a request using the contact details specified below in clause 13. All processing actions carried out before the revocation of consent remain in force.

How will we inform you about changes to the Policy?

We may make changes to this policy from time to time. We will post the changes on this page and notify you via email or platform. If you do not agree to the terms set forth in this document, do not use the website and the services provided through it.

Your rights

In certain circumstances, you have rights under the privacy law. If you wish to exercise any of the following rights, please contact us using your contact details.

The right to request access to your personal data (commonly referred to as "requesting access to the data subject"). This allows you to obtain a copy of the personal data we hold about you and to ensure that we process it legally.

The right to request the correction of any data we hold about you. This allows you to correct any incomplete or inaccurate data we hold about you, although you may need to verify the accuracy of the new data you provide to us.

The right to request a restriction on the processing of your personal data. This allows you to ask us to suspend the processing of your personal data in the following cases: (a) if you wish to establish the accuracy of the data; (b) if we use the data illegally; (c) if you need to save the data, even if we no longer need it, but you need it to prepare and file legal applications; (d) if you object to the use of your data and we must ensure that there is a convincing legal basis for its use.

The right to request the deletion of your personal data. This allows you to ask us to delete or destroy your personal data if there is no compelling reason to continue processing it. You also have the right to ask us to delete or destroy your personal data if you have successfully exercised your right to object to its processing (see below), if we have processed your data illegally. or if we are required to delete your personal data in accordance with local law. Please note that for certain purposes, we are legally obliged to store your data. See section 9 for details.

The right to object to the processing of your personal data if we rely on legitimate interests (or the interests of third parties), but any circumstances in your particular situation lead you to oppose the processing of data, because you believe that this affects your rights and freedom the base. You also have the right to object if we process your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legal grounds for the processing of your data that go beyond your rights and freedoms.

The right to request the transfer of your personal data to you or to third parties. We will provide you or your third parties with your personal data in a widely used structured format that can be read using a computer. Please note that this right only applies to automatically collected data for which you originally granted us or if we have used this data to fulfill a contract with you.

The right to revoke your consent to the processing of your personal data at any time. This does not affect the legality of any data processing we have already carried out on the basis of the aforementioned consent.

In general, no fees are required and you will not have to pay to access your personal data or to exercise any other rights. However, we may charge a reasonable fee if your request is manifestly unfounded, repeated or exaggerated. Otherwise, in such circumstances, we may refuse to grant your request.

Answer time: we try to answer all legitimate questions within a month. If your request is particularly complex or you have made multiple requests, it may take more than a month to receive a response. In this case, we will notify you and keep you informed.

In addition, you have the right to file a complaint with the data protection authority at any time. Contact details can be found in section 13.

However, before you file a complaint with a data protection authority, we are ready to address your concerns first. Please contact support for this.

Marketing emails

We will contact you by email, SMS or notification from the Service / Platform application to confirm your registration on the Platform, to inform you if the registration of the ad is valid / expired and for other transactional messages related to our Services. Because we are required to provide you with such transactional messages, you cannot opt ​​out.

However, you can unsubscribe from the newsletter at any time by following the link in an email or SMS message or by contacting us via support.

You can receive marketing communications from us if:

- you have requested such information from us;

- use our platform or services

- you provided us with the data when you participated in the contest or registered to participate in the promotion.

To whom do we disclose your data?

Personal data may be disclosed to the parties listed below for the purposes set out above in section 3.

Affiliated companies. We may share your information with other Three Spheres companies to provide you with business services, such as product improvement, customer support, and fraud detection. Any exchange of personal data will be subject to the precautions described in section 10 and will comply with a data transfer agreement that clearly defines the obligations of the parties and provides technical and organizational measures for the protection of personal data.

Third party service providers. We work with third-party service providers to help us deliver certain aspects of the service. Third party service providers can be located both inside and outside the Republic of Moldova.

In order to make payments on our platform, whether it is payment by card or payment by payment order, we use the services of commercial banks, payment processors authorized by us to perform these operations in accordance with the legislation of the Republic of Moldova. In this regard, when we make payments for the purchase of services on our platform, we will transfer some of your personal data to a commercial bank for the purpose of processing payments and completing the corresponding transaction.

We review third-party service providers and ask them to respect the security of your personal information and to treat it in accordance with the law. We do not allow the use of your personal data for our purposes, we allow the processing of personal data only for specific purposes and only in accordance with our instructions.

Advertising and analysis providers. In order to improve our Services, we will sometimes share your data with data analytics providers who help you analyze the use of your data by our Platform / Services. We provide you with data in an unidentifiable form for monitoring and reporting on the effectiveness of advertising campaigns for our business partners and for internal analysis of companies. This information typically includes a cookie ID, an IP address (abbreviated), a referral URL, and browser and device information. We cooperate with BATI, a non-profit organization involved in the media and advertising industry, whose members are print and online publishers, advertisers and their clients, as well as various advertising providers, including S.R.L.

Prosecutors, government agencies and others: We may disclose your personal information to prosecutors, government authorities or government agencies and other relevant organizations in accordance with the law or regulations. We may sell, transfer or combine parts of our business or assets. Alternatively, we may seek acquisitions or mergers with other companies. If there are changes in our company, new owners may use your personal data in the same way as in this policy.

Publicly Available Information: When you post a product for sale through our Services, you may make certain personal information visible to other users of the Site. They can see your first and last name, email address, your location and your contact number. Please note that all information you provide to other users can always be passed on to other users, so please be careful.

International transfers

When we transfer your personal data to a country outside the European Union, we ensure that the same degree of protection is ensured by implementing at least one of the following guarantees:

• We will only transfer personal data to countries where the level of protection of personal data is considered appropriate by the European Commission. For more information, see the European Commission: Adequacy of personal data protection in non-EU countries.

• If we work with certain service providers, we may use special contracts approved by the European Commission, following which the protection of personal data provided will comply with EU regulations. For more information, see the European Commission: model contracts for the transfer of personal data to third countries.

• If we do business with US service providers, we may share data with them if they are part of a privacy shield policy that requires them to provide adequate protection for personal data transferred between Europe and the US. For more information, see the European Commission: EU-US Privacy Shield.

Where and for how long do we store your data?

The data we collect about you will be stored and processed on secure servers both on the territory of the Republic of Moldova and abroad. This is done to give users the best possible experience, for example, to create quickly web pages or mobile applications.

We will retain your personal data for as long as is necessary to achieve the purposes we have provided when we collect it, including to meet any legal, accounting or reporting requirements.

To determine the storage time required for personal data, we consider the amount, nature and confidentiality of your data, the potential risk of harm caused by unauthorized use or disclosure of your personal data, the purposes for which we process your data and the possibility of achieving such purposes. by other means in accordance with applicable legal requirements.

If your account is inactive for 12 months, we reserve the right to delete your account, including any personal data stored in your account, which means that you will no longer be able to access and use it. However, you can be assured that we will not delete your account if you have open transactions or are eligible for a repayment or loan from us. Before deleting your account, we will contact you to ensure that you do not want to continue using your account.

Technical and organizational measures and safety of processing

All information we receive about you is stored on secure servers and we have taken appropriate technical and organizational measures to protect your personal data. We continuously evaluate network security and its compliance with our internal information security program, which is designed to: (a) protect your data from accidental or unlawful loss, access or disclosure; (b) to identify reasonably foreseeable security risks to our network; and (c) to minimize security risks, including risk assessment and periodic testing. In addition, we guarantee that all payment information is encrypted using SSL technology.

Please note that despite the measures we have taken to protect your data, the transmission of information via the Internet or other open networks is never completely secure and there is a risk that your personal data may be accessed by unauthorized third parties. .

Links to third party sites

Our platform may contain links to third party websites or applications. If you use one of these links, please note that each of these sites or applications will have its own privacy policies. We do not control these websites / applications and are not responsible for their policies. When you leave our platform, we recommend that you read the privacy policy of each website you visit.

Principles for the processing of personal data

The processing of personal data is based on the following principles:

- the legality of the purposes and methods of personal data processing and good faith;

- the compliance of the purposes of the processing of personal data with the purposes defined above and stated when collecting personal information;

- compliance with the volume and nature of the personal data processed, the methods of processing personal data in connection with the purpose of data processing;

- the reliability of the personal data, the relevance and the necessary volume of their processing, the inadmissibility of the excessive processing in relation to the purposes of the collection of the personal data;

- the legality of organizational and technical measures to ensure the security of personal data;

- efforts to continuously improve the system of personal data protection.

Identification and contact information

For more information or to exercise your rights, please contact customer support by phone or email.

Working hours:

Monday-Friday from 09:00 to 18:00;

Lunch break 12:00 -13: 00 / 13:00 -14: 00;

Free days: Saturday, Sunday.

24/7 customer support: + (373) 69503961