PRIVACY POLICY

Latest version is of October 04, 2022

This Privacy Policy (hereinafter referred to as the “Policy”) sets forth the general rules of collection, processing, distribution, use and storage of website www. (hereinafter the “Website”) user’s Personal data including any dispute concerning privacy under current General Data Protection Regulation (GDPR), and in accordance with the data protection regulations in Hungary applicable to the Upgrade Solutions Kft. (hereinafter the “Upgrade Solutions Kft.”, “Company”, “Us”, “We”) with its registered address at: Verebeshegy utca 11, Csomád, 2161, Hungary, gathers from Users who use the Website.

It is understood and presumed that by the fact of use of the Website and its services or by clicking “I Accept Terms and Conditions and Privacy Policy” button the User gives Consent, that he/she/it has fully read, understood and accepted this Policy. If any User does not agree with this Policy in general or any part of it, such User should withhold from using the Website and its services. By continuing to use our Website, you acknowledge that you have had the chance to review and consider this Privacy Policy, and you acknowledge that you agree to it. This means that you also consent to the use of your information and the method of disclosure as described in this Privacy Policy. If you do not understand the Privacy Policy or do not agree to it, then you agree to immediately cease your use of our Website.

This Privacy Policy may be modified, changed, supplemented, updated at any time with prior written notice from Company. Your continued use of the Website and its services after any amendments or alterations of this Privacy Policy without notification of Company shall constitute your consent hereto and acceptance hereof of an updated version of this Privacy Policy. At any case, the date of the most recent amendments and alterations will be indicated at the top of this web page. If the User does not agree to such revised terms of the Privacy Policy or Terms of Use he/she/it must stop using this Website and may withdraw from his/her/its obligations under this Privacy Policy.

DEFINITIONS

The following definitions and rules of interpretation apply in this Privacy Policy:

For the purposes of this Regulation:

“Personal data” means any information, that we obtain from you in connection with your use of the Website, relating to an identified or identifiable natural person (”data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

“Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“Restriction of processing” means the marking of stored personal data with the aim of limiting their processing in the future;

“Parties” to this Privacy Policy are the following data controller: Upgrade Solutions Kft. ("Data Controller") and you, as the user of this Website. Hereinafter, the parties will individually be referred to as "Party" and collectively as "Parties."

“Data Controller” is the publisher, owner, and operator of the Website and is the Party responsible for the collection of information described herein. Data Controller shall be referred to either by Data Controller's name or "Data Controller," as listed above. If Data Controller or Data Controller's property shall be referred to through first-person pronouns, it shall be through the use of the following: us, we, our, ours, etc.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

“Effective Date” means the date this Privacy Policy comes into force and effect.

“Services” mean any services that we make available for sale on the Website.

“Cookie” is a text file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Should you agree to this Privacy Policy and continue your use of the Website, you will be referred to herein as either "you", "the user", "your", "yours", etc.

DATA PROTECTION OFFICER AND CONTACT

The data controller of this Website is Upgrade Solutions Kft. located at: Verebeshegy utca 11, Csomád, 2161, Hungary.

Contact details: support@zenofmybody.com.

The Data Controller and operator of the Website are one and the same.

The Data Protection Officer is Vitalii Demnichenko.

Contact details:

support@zenofmybody.com.

Verebeshegy utca 11, Csomád, 2161, Hungary.

COLLECTION AND PROCESSING OF PERSONAL DATA

Depending on how you use our Website, you will be subject to different types of Personal Data collected and different manners of collection.

During the process of your registration, we may collect some of the following Personal Data from you through your voluntary disclosure:

information you provide to us when ordering our services through this Website, or information which is generated in the course of the use of those services;
information contained in or relating to any communication that you send to us or send through this Website (including correspondence with us, communication content and metadata associated with the communication);
if you have agreed to cookies, data such as your Website preferences or language settings. We can also use this information in an aggregate manner to understand how our visitors navigate this Website so we can make it better;
any other personal data that you choose to send to us;
any technical data from various third parties and public sources (including from analytical providers, advertising networks, search information providers).

USE OF PERSONAL DATA

Any information collected by our Company will be used in accordance with this Privacy Policy for the purposes they were collected and for the time necessary for these purposes. Access to personal data is provided exclusively to employees and contractors of the Company who have the appropriate permission and a clear operational need for access to data.

USE OF COOKIES

We use or may use different types of Cookies, namely:

Analytical/performance cookies. They allow us to collect information about how you use our website, including your operating system and platform, browser info, domain name of the website previously visited, number and average duration of visits, pages viewed. This information is used to improve usability and user experience of a website. These cookies do not collect information that personally identifies you.
Functionality Cookies, Our website uses these cookies to recognize you when you return to our website and to personalize website content and our services for you, for example, remember chosen language or include your geolocation into your requests for proposal.
Targeting Cookies. Including third party service performance and retargeting Cookies, such as the Google Analytics, Google AdWords, Google Tag Manager, Facebook Pixel, to analyze information about your web browsing behavior on our website, to provide you ads that meet your interests, and to manage the effectiveness of advertisements.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Please refer to your browser help menu for additional information about how to disable cookies. If you disable or refuse cookies, some parts of our website may not function properly.

SHARING OF PERSONAL DATA

We may disclose your personal information to third parties:

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms or supply terms and other agreements with you; or to protect the rights, property, or safety, our customers, employees and partners
To satisfy any local or state laws or regulations;
To respond to requests, such discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies;
As may be necessary for the operation of our Website;
To generally cooperate with any lawful investigation about our users;
If we suspect any fraudulent activity on our Website or if we have noticed any activity which may violate our terms or other applicable rules.

Related Entities: We may share your Personal Data, including Personal Data that identifies you personally, with any of our parent companies, subsidiary companies, affiliates or other trusted related entities.

However, we only share your Personal Data with a trusted related entity if that entity agrees to our privacy standards as set out in this Privacy Policy and to treat your Personal Data in the same manner that we do.

Third Parties: We may engage third-party service providers ("Third-Party Service Providers"), from time to time or all the time, to help us with our Website, and to help serve you. We may use Third-Party Service Providers to assist with information storage (such as cloud storage).
We may provide some of your Personal Data to Third-Party Service Providers in order to help us track usage data, such as referral websites, dates and times of page requests, etc. We use this information to understand patterns of usage of, and to improve, the Website. We may use Third-Party Service Providers to host the Website. In this instance, the Third-Party Service Provider will have access to your Personal Data. We only share your Personal Data with a Third-Party Service Provider if that provider agrees to our privacy standards as set out in this Privacy Policy. Notwithstanding the other provisions of this Privacy Policy, we may provide your Personal Data to a third party or to third parties in order to protect the rights, property or safety, of us, our customers or third parties, or as otherwise required by law. We will not knowingly share your Personal Data with any third parties other than in accordance with this Privacy Policy.
If your Personal Data might be provided to a third party in a manner that is other than as explained in this Privacy Policy, you will be notified. You will also have the opportunity to request that we not share that information.
In general, you may request that we do not share your Personal Data with third parties. Please contact us via email, if so. Please be advised that you may lose access to certain services that we rely on third-party providers for.

Disclosure of Information: We may disclose any information we collect about you, whether you are a current or former customer, including non-public personal information and any other information we collect, to Upgrade Solutions Kft. affiliated companies and to non-affiliated third parties, which include non-financial companies, such as service providers and fraud verification services.

Such cases may include, but are not limited to:
a) To satisfy any local or state laws or regulations;
b) To respond to requests, such discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies;
c) To bring legal action against a user who has violated the law or violated the Terms and Conditions of our Website;
d) As may be necessary for the operation of our Website;
e) To generally cooperate with any lawful investigation about our users;
f) If we suspect any fraudulent activity on our Website or if we have noticed any activity which may violate our terms or other applicable rules.

NDA INFORMATION IN THE PUBLIC DOMAIN

We are fully aware that confidentiality is critical for our clients. Disclosure of any data concerning our cooperation with any client, including the cooperation itself, is forbidden by default. This is true even before the NDA is signed. Disclosure is possible only with a clear permission from all parties involved.

While we are aware that such a policy is limiting the promotion of our services, especially with respect to testimonials, the success of our clients in the long term is far more important to us than a momentary benefit from an advertisement of our capabilities.

SECURITY AND STORAGE OF PERSONAL DATA

We process personal data by applying appropriate technical and organizational measures to protect personal data from accidental or illegal destruction or accidental loss, alteration, unauthorized disclosure or access, particularly if processing involves the transmission of data over the network, as well as protection against other forms of misuse.

We ensure that your Personal Data is protected against unauthorized access, disclosure, or destruction.

Please note, however, that no system involving the transmission of information via the internet, or the electronic storage of data, is completely secure. However, we take the protection and storage of your Personal Data very seriously. We take all reasonable steps to protect your Personal Data.

Personal Data is stored throughout your relationship with us. We delete your Personal Data upon request for cancellation of your account or other general request for the deletion of data.

We will store your information for as long as we have to by law. If there is no legal requirement for us to retain the data, we will only store it for as long as we need to.

In the event of a breach of your Personal Data, you will be notified in a reasonable time frame, but in no event later than two weeks, and we will follow all applicable laws regarding such breach.

Primarily we use your Personal Data to help us provide a better experience for you on our Website and to provide you the services and/or information you may have requested, such as use of our Website.

Information that does not identify you personally, but that may assist in providing us broad overviews of our customer base, will be used for market research or marketing efforts. Such information may include, but is not limited to, interests based on your cookies.

Personal Data that may be considering identifying may be used for the following:

a) Improving your personal user experience
b) Communicating with you about your user account with us
c) Fulfilling your purchases
d) Providing customer service to you
e) Advising you about updates to the Website or related Items

YOUR RIGHTS

You have the following rights in relation to personal data relating to you that we process:

Request access to your personal data and to the information regarding its processing;
Request correction and updates of incorrect or incomplete information about you;
Request deletion of your personal data stored by us;
Object to processing or restrict processing your personal data;
Request portability of your personal data;
If we process your personal data based on your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal;
Complain to a data protection authority about our collection and processing of your personal data.

To use your rights, request access, correction, deletion, restriction, portability of your personal data or to withdraw you consent to data processing:

Email us at support@zenofmybody.com.

Refusal to receive information from the Company: From time to time, we may send you informational or marketing communications related to our Website such as announcements or other information. If you wish to opt-out of such communications, you may contact the following email: support@zenofmybody.com. You may also click the opt-out link which will be provided at the bottom of any and all such communications.
Please be advised that even though you may opt-out of such communications, you may still receive information from us that is specifically about your use of our Website or about your account with us.
By providing any Personal Data to us, or by using our Website in any manner, you have created a commercial relationship with us. As such, you agree that any email sent from us or third-party affiliates, even unsolicited email, shall specifically not be considered SPAM, as that term is legally defined.

ACCESSING, MODIFYING AND DELETING YOUR INFORMATION

If you wish to modify or delete any information we may have about you, or you wish to simply access any information we have about you, you may do so by sending us the request to support@zenofmybody.com.
EU Representative (in accordance with the EU GDPR):
Due to our business being located within the EU we do not require to appoint a representative.
Complaints
If you have any issue or complaint, please contact the above mentioned DATA PROTECTION OFFICER for all enquiries. We will treat your complaint in confidence and acknowledge receipt of a complaint within 24 hours and we will send you a full reply within 5 working days of receipt.
If a complaint is very complex, it may occasionally be necessary to extend the time limit. We will keep you informed of progress, the reasons for the delay, and the new deadline.
If your complaint is not resolved to your satisfaction within 24 hours, or through the conclusion of the informal complaints process, you can contact our DATA PROTECTION OFFICER with details in writing regarding your wish to make a formal complaint. If you are not happy with how we handle any complaint, you are able to raise a complaint at any time with your country’s national data protection authority. If you live in the UK, this would be the Information Commissioner’s Office.

RISK ACCEPTANCE

By continuing to our Website in any manner, use the Product, you manifest your continuing asset to this Privacy Policy. You further acknowledge, agree and accept that no transmission of information or data via the internet is not always completely secure, no matter what steps are taken. You acknowledge, agree and accept that we do not guarantee or warrant the security of any information that you provide to us, and that you transmit such information at your own risk.

CHILDREN‘S PRIVACY

The Website and any products or Services available on Website are not intended to solicit information of any kind from persons under 18 years of age or any other age of legal majority existing in the jurisdiction of the User.

SECURITY

Company use relevant electronic and procedural safeguards to protect the privacy of the information the User provides to Company from loss, misuse, disclosure, alteration and destruction. Please note that transmission of data or information (including communications by e-mail) over the Internet or other publicly accessible networks is not one hundred percent secure. Please note that Company are not liable for the security of any data Users are transmitting over the Internet, or third party content.

CONTACT INFORMATION

If you wish to contact us and ask additional questions about this Privacy Policy or the way we collect information from you, or if you would like to launch a complaint about anything related to this Privacy Policy, you may contact us at the following email address: support@zenofmybody.com.

CHANGES TO THIS POLICY

We are constantly improving ways of collecting, storing and processing data, including the Privacy Policy. We may, at any time, change this Policy by, when appropriate, notifying the Users about it on our website.