PRIVACY POLICY

The Privacy Policy of ALOTO INTERNATIONAL LLC is designed to ensure the highest possible level of protection of the User's personal data.

In this document, you can find a list of the User's data that is processed; the purpose of processing; methods and terms of processing personal data; the rights granted to the User, as well as other provisions regarding the processing of personal data. If you still have any questions after reading this document, you can always send a letter to obtain the necessary information by sending it to the following address: support@aloto.com.

1.1.1. “Website Administration” - ALOTO INTERNATIONAL LLC (registration number: 45262804), represented by Director Artem Gursky and persons duly authorised to manage the Website and provide services to the User, who organise and process personal data, as well as determine the purposes of processing personal data, the composition of personal data to be processed, actions or operations performed with personal data.

1.1.2. ”Website” - a collection of data, electronic (digital) information, including copyright and/or related rights, etc., interconnected and structured within the https://aloto.com/ address, accessed through an Internet address that may consist of a domain name, directory or call records and/or a numerical address according to the Internet protocol.

1.1.3. “Web page” - an integral part of the Website located at a special address on the Internet.

1.1.4. “Confidentiality of personal data” - the requirement not to allow the distribution of personal data (mandatory for compliance by the Administrator or another person who has access to personal data) without the consent of the subject of personal data or the presence of another legal basis. mandatory for compliance by the Administrator or another person who has gained access to personal data.

1.1.5. “User” - a person who uses the Website and has agreed to comply with the Website Terms and conditions.

1.1.6. “Personal data” - any information relating directly or indirectly to an individual (subject of personal data).

1.1.7. “Processing of personal data” - any action (operation) or set of actions (operations) carried out with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1.1.8. “ALOTO INTERNATIONAL LLC” - LIMITED LIABILITY COMPANY “ALOTO INTERNATIONAL”, register number: 45262804, registered address: Ukraine, 01023, Kyiv city, sq. Sportivna, building 1a, office 151, registered and operates under the legislation of Ukraine in the person of the Director Hurskyi Artem, who is acting based on the Articles of Association.

1.1.9. “Cookies” - a small piece of data sent by a web server and stored on a user's computer, which a web client or web browser sends to the web server each time it tries to open a page of the corresponding Website in an HTTP request.

1.1.10. “IP address” - is a unique network address of a node in a computer network built according to the IP protocol.

2.2. In case of disagreement with the terms of the Privacy Policy, the User must stop using the Website.

2.3. This Privacy Policy applies only to the Website. The Website Administration does not control the possibility of transition and is not responsible for third-party websites to which the User can follow the links available on the Website.

2.4. The Website Administration does not verify and is not responsible for the accuracy of personal data provided by the User.

2.5. The User has the right to:

2.5.1. to know about the sources of collection, the location of their data, the purpose of their processing, the location or place of residence (residence) of the owner or manager of personal data or to give an appropriate mandate to obtain this information to persons authorized by him, except for cases established by law;

2.5.2. to receive information about the conditions of providing access to personal data, in particular, information about third parties to whom his data is transferred; 

2.5.3. have access to your data;

2.5.4. enter a reservation regarding the limitation of the right to process your data when giving consent;

2.5.5. withdraw consent to the processing of personal data;

2.5.6. file complaints about the processing of your data;

2.5.7. present a reasoned demand to the owner of personal data with an objection to the processing of his/her data;

2.5.8. to submit to the Website Administration a request for correction or destruction of personal data;

2.5.9. to receive personal data provided by the User to the Website Administration and to transfer it freely to other personal data administrators;

2.5.10. require the Website Administration to disclose the following information:
(a) categories of personal data that the Website Administration has collected about the User;
(b) categories of sources from which personal data is collected;
(c) business or commercial purpose of collecting personal data;
(d) categories of third parties to whom the Website Administration discloses personal information;
(e) specific parts of personal data that the Website Administration has collected about the User.

2.6. The Website will not discriminate against you or take any action against you for exercising the rights set forth in Chapter 2 of this Policy.

2.7. The legal grounds for the personal data processing are:
(a) Clause “a” of paragraph 1, Article 6 GDPR: Your consent of processing for Your personal data for the purposes stated in Clause 4.1 of this Policy;
(b) Clause “b” of paragraph 1, Article 6 GDPR: in case the processing of Your personal information is required for the performance of a contract to which You are the subject.

2.8. The Website Administration does not sell or transfer the collected personal data (within the meaning of the California Consumer Privacy Act).

2.9. The Website Administration respects the ‘Do Not Track’ (DNT) signals and does not track, set cookies or use advertising when the DNT mechanism is installed in the browser. The Website Administration does not allow third parties to track user behaviour.

2.10. This Privacy Policy has been developed to confirm the compliance of the services provided by the Website with the provisions of the Law of Ukraine “On Personal Data Protection”, the General Data Protection Regulation, namely Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (“GDPR”), the California Consumer Privacy Act of 2018 (“CCPA”), the California Online Privacy Protection Act ("CalOPPA"), the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Utah Consumer Privacy Act (“UCPA”) and other laws governing the interaction with personal data of Internet users.

3.2. The personal data permitted for processing under this Privacy Policy is provided by the User at his/her choice by filling out the appropriate forms on the Website or by going to the Website.

3.2.1. When filling out the “Become a Shopper” form on the Website, the User shall provide the following information to the Website Administration:
- User's name;
- User's e-mail.

3.2.2. When filling out the “Become a Shaper” form on the Website, the User transfers the following information to the Website Administration:
- User's name;
- User's e-mail;
- User's phone number.

3.2.3. The Website uses cookies. The procedure for data processing and the amount of data to be processed using Cookies are set out in the Cookie Notice, which is available at: (aloto.com/cookie-notice).

3.3. The Website protects the Data that is automatically transmitted in the process of viewing ad units and when visiting pages on which the system's statistical script (‘pixel’) is installed: IP address; information from cookies; information about the browser (or other program that accesses the advertisement); time of access; address of the Website where the ad unit is located; referrer (address of the previous page).

3.3.1. Disabling cookies may result in the inability to access parts of the Website or the Website as a whole, taking into account the current modification of the Website functionality.

3.3.2. The Website collects statistics about the IP addresses of its Users. Such information is used to identify and resolve technical problems.

3.4. Any other personal information, except for the above (browsers, operating systems, etc.), is subject to secure storage and non-disclosure, except as provided for in clauses 5.2 - 5.3 of this Privacy Policy.

4.1.1. Identification of the Website User to respond to a request, application of the User;

4.1.2. Providing the User with access to personalised resources of the Website.

4.1.3. Establishing feedback with the User, including sending notifications, requests regarding the use of the Website, providing potential services.

4.1.4. Determining the location of the User to ensure security and prevent fraud.

4.1.5. Confirmation of the accuracy and completeness of personal data provided by the User.

4.1.6. Providing the User with effective customer and technical support in case of problems related to the use of the Website.

4.1.7. Providing the User with product updates, special offers, pricing information, newsletters and other information on behalf of the Website with his/her consent.

4.1.8. Carrying out advertising activities with the consent of the User.

4.1.9. Providing the User with access to the Website or services of partners of ALOTO INTERNATIONAL LLC in order to obtain products, updates and services.

5.2. The User agrees that the Website Administration, in order to provide the service to the User, is authorised to transfer personal data to third parties, including, but not limited to, telecommunication operators, foreign subjects of relations related to the processing of personal data. We are also authorised to store and use the User's information to comply with our legal obligations and prevent abuse.

5.3. The User's data may be transferred to the authorized bodies of the state authorities of Ukraine only on the grounds, conditions, and in the order established by the current legislation.

5.4. In case of loss or disclosure of personal data, the Website Administration shall inform the User about the loss or disclosure of personal data.

5.5. The Website Administration shall take all available and necessary organisational, technical and legal measures to protect the User's personal information from unauthorised or accidental access, destruction, blocking, copying, modification, distribution, dissemination, as well as from other illegal actions of third parties.

5.6. The Website Administration together with the User shall take all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.

6.1.1. Provide information containing personal data necessary to use the Website.

6.1.2. Update, supplement the provided information containing personal data in case of changes in this information.

6.2. The Website Administration is obliged to:

6.2.1. Use the information received solely for the purposes specified in Section 4 of this Privacy Policy.

6.2.2. Ensure that confidential information is kept confidential, not disclosed without the prior written consent of the User, and not to sell, exchange, publish, or disclose in any other way the transmitted personal data of the User, except for clause 5.3 of this Privacy Policy.

6.2.3. Take precautions to protect the confidentiality of the User's personal data in accordance with the procedure generally used to protect this type of information in the existing business environment.

6.2.4. To block personal data relating to the relevant User from the moment of application or request of the User or his legal representative or authorised body for the protection of the rights of personal data subjects for the period of verification, in case of detection of inaccurate personal data or illegal actions.

7.2. In case of loss or disclosure of Confidential Information, the Website Administration shall not be liable if this information is confidential:

7.2.1. Became public domain before its loss or disclosure.

7.2.2. Was received from a third party before it was received by the Website Administration.

7.2.3. Was disclosed with the consent of the User.

7.2.4. Was disclosed through the fault of the User.

8.2. The recipient of the claim shall, within 30 calendar days from the date of receipt of the claim, notify the claimant in writing of the results of the consideration of the claim. 

8.3. In case of failure to reach an agreement, the dispute will be referred to a judicial authority in accordance with the current legislation of Ukraine. 

8.4. The current legislation of Ukraine applies to this Privacy Policy and the relationship between the User and the Website Administration.

9.2. The new version of the Privacy Policy comes into force from the moment it is posted on the Website, unless otherwise provided by the new version of the Privacy Policy.

9.3. The User confirms that he/she has read and understands the provisions of this Privacy Policy and accepts the terms and conditions.

9.4. All suggestions, comments, complaints or questions regarding this Privacy Policy, as well as requests, including those regarding the exercise of the rights provided for in Section 2 of this Privacy Policy, should be communicated by sending an e-mail to the following address: support@aloto.com

9.5. The current Privacy Policy is available on the Web page at: (http://aloto.com/privacy-policy).

9.6. In compliance with the requirements of the legislation of Ukraine regarding the protection of personal data, we inform you that the controller is a legal entity registered on the territory of Ukraine: Limited Liability Company "ALOTO INTERNATIONAL", EDRPOU code: 45262804, registered address: Ukraine, 01023, Kyiv city, sq. Sportivna, building 1a, office 151, which is registered and operates under the laws of Ukraine in the person of the director Artem Petrovych Gursky, who operates based on the Articles of Association.

9.7. For Users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018. We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.

We may amend this Privacy Policy from time to time to maintain compliance with the law to reflect any changes to our data collection process. We recommend you check this Privacy Notice from time to time to ensure you are aware of any changes. If necessary, we may notify you by mail of changes to this Privacy Police.