PRIVACY POLICY
(for users from eu and us)
GENERAL PROVISIONS

This document defines the policy BRT Solutions Ltd, a legal entity incorporated under the laws of the Republic of Cyprus with registered address at: Peiraios, 30, 1st Floor, Flat/Office 1, Strovolos, 2023, Nicosia, Cyprus ("Kroog") regarding the processing of Personal Data of Users of the Kroog service and the Kroog mobile app (hereinafter also referred to as the "Policy"). If you have any questions about our Privacy Policy, our collection practices, the processing of user information, or if you would like to report a security violation to us directly, please contact us at data@kroog.io

Your Consent: The User shall fully read this Policy before using the mobile application Kroog (hereinafter referred to as the "Service"). Using the Service and filling out any forms by the User shall mean full and unconditional acceptance of the Policy by the User.

This document is publicly available and is available on the official web page www.kroog.io and in the mobile app.

Kroog shall be entitled to make changes to this Policy, for reasons related to working practices or regulatory changes, without prior notice to the User and/or obtaining approval from the User. When changes are made, the date of the last revision update shall be indicated in the Policy header. The new version of the Policy shall take effect upon it is posted on the Service, unless otherwise provided by the new version of the Policy. In this regard, we recommend that you read the Policy when you re-visit the Service.

Kroog may, at its sole discretion, notify the User of the addition and / or modification of this Agreement in the manner that Kroog deems most appropriate. Using the Service, the materials and functions offered on it at any time means that the User unconditionally accepts all the terms and conditions of this Agreement. If the User does not agree with the current version of this Agreement in whole or in part, the User shall immediately request Kroog to delete his account and stop using the Service until his account is deleted.

Using the Service, the User fully and unconditionally accepts this Policy, including by downloading, installing, using the Service and filling out any forms posted on it, the User confirms his consent to the Kroog processing of Personal Data and other information provided during registration, collected automatically, as well as placed by the User voluntarily on his personal page in the personal account, including, but not limited to User generated content: comments, reviews, descriptions, reviews, design elements, photos, videos, images, drawings, sound files, links to third-party resources.

WHAT DATA WE COLLECT

The use of our services will automatically create information that will be collected. For example, when you use our Services, your geographic location, how you use the Services, information about the type of device you use, your Open Device Identification Number, date/time stamps for your visit, your unique device identifier, your browser type, operating system, Internet Protocol (IP) address, and domain name are all collected. This information is generally used to help us deliver the most relevant information to you and administer and improve the Service.

Log Files: As is true of most Service, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to maintain and improve the performance of the Services.

Analytics: We use analytics services (including, but not limited to, Google Analytics) to help analyze how users use the Service. Analytics services use Cookies to collect information such as how often users visit the Service and we use the information to improve our Service. The analytics services' ability to use and share information collected by them is restricted by their terms of use and privacy policy, which you should refer to for more information about how these entities use this information.

Location Information: If you have enabled location services on your mobile device, we may collect your location information to improve the Services we offer. If you do not want this information collected, you can disable location services on your device.

Cookies: "Cookies" are small pieces of information (text files) that a Service sends to your computer's hard drive while you are viewing the Service. These text files can be used by the Service to make the users experience more efficient. The law states that we can store these cookies on your device if they are strictly necessary for the operation of this Service. For all other types of cookies we need your permission. To that end, this Service uses different types of cookies. Some cookies are placed by third party services that appear on our pages. We and some third parties may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services and to market the Services or other products. Marketing cookies are used to track visitors across Service. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
Kroog collects and / or processes Personal Data for the purpose of registering the User on the Service, enabling its full use, providing the User with services offered by the Service and other Users, and participating in research and marketing activities conducted by Kroog. Kroog collects and stores only Personal Data that is necessary for the provision of the Service or the performance of agreements and contracts with the User, except in cases where the law provides for mandatory storage of Personal Data for a period specified by law, including for the PURPOSE OF:
* User identification;
* providing the User with personalized services;
* communication with the User, including sending notifications, requests and information related to the use of the Service, the provision of services, as well as processing User's requests;
* conducting statistical and other research based on depersonalized data;
* conducting marketing campaigns for Users, including for the purpose of distributing offers to participate in the promotion and receiving prizes/rewards provided for by the promotion;
* distribution of advertising and information materials over telecommunication networks, including through the use of telephone, Internet, mobile radiotelephone communications, or through direct contacts;
* to resolve disputes and identify problems;
* to prevent potentially prohibited and illegal actions;
* targeting newsletters, advertising materials and other information brought to the attention of Users.

We may store and process your personal information on servers located in both the United States and Europe. We may also create anonymous data records from your personal information by completely excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of our Services and improve Service functionality. We reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties at our sole discretion.

We may receive testimonials and comments from users who have had positive experiences with our Services. We may publish such content. When we publish this content, we may identify our users by their first and last name. We obtain the user's consent prior to posting this information along with the testimonial.

PERMITTED DISCLOSURE OF PERSONAL INFORMATION

Kroog disclose your personal information as described below and as described elsewhere in this Privacy Policy.

Third Parties Designated by You: When you use the Service, the personal information you provide will be shared with the third parties that you authorize to receive such information.

Third Party Service Providers: We may share your personal information with third party service providers to: provide you with the Services that we offer you through our mobile app; conduct quality assurance testing; to provide technical support; market the Services; and/or to provide other services to us.

Information We Share: We may disclose aggregated information about our users and information that does not identify any individual without restriction. In addition, we may disclose personal information that we collect or you provide:
* To fulfill the purpose for which you provide it, for any other purpose disclosed by us when you provide the information, or
with your consent;
* To third parties designated by you;
* With our subsidiaries and affiliates;
* To third parties to process payments made through the Services;
* With contractors, service providers and other third parties we use to support our business;
* To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about users is among the assets transferred.

Other Disclosures: Regardless of any choices you make regarding your Personal information (as described below), Kroog may disclose Personal information if it believes in good faith that such disclosure is necessary: (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on our company; (iii) to protect or defend the rights or property of lipsum.com or users of the Services; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

Procedure and Conditions For Processing Personal Data

Kroog shall be entitled to:
* perform any actions (transactions) or a set of actions (transactions) performed using automation tools or without using automation tools with its Personal Data (processing of Personal Data), including collection, recording, copying, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (provision, access) to third parties, as well as in cases directly provided for by the applicable law, in compliance with the requirements of information confidentiality, depersonalization, blocking, deletion, destruction of Personal Data, and confirms that by giving such consent, it acts on own accord and in own interest.
* use cookies and similar technologies (including: pixel tags, web beacons, transparent GIF files, JavaScript and local data storage, etc.) to collect personal identification information or information that can become personal identification information in combination with other information, in compliance with all necessary legal requirements regarding the privacy of Users' Personal Data, by identifying Users, counting their number and observing which pages of the Service they visit, to ensure maximum User convenience by providing personalized information, remembering preferences in marketing and products, as well as helping to get the right information (including for entering the protected areas of the Service or for using the personal account, internal modules of the Service functionality), analyzing User's actions on the Service, in order to improve and optimize the Service, including, to make it easier for visitors to find the necessary information on the Service;
* provide advertising, messages and content, including by sending push or SMS notifications (messages), advertising notifications and messages, via e-mail on the Internet, using the services and databases of both the Service itself and the services of third-party (external) Services and resources on the Internet;
* communicate directly with the User, including via telephone, mobile device, email.

Kroog may use the User-provided information, including Personal Data, to ensure compliance with the requirements of applicable law (including, for the prevention and/or suppression of Users' illicit and/or illegal actions). Disclosure of the information provided by the User can be made only in accordance with the applicable law at the request of the court, law enforcement agencies, as well as in other cases provided by law.

Personal Data shall be processed upon the User fills out the appropriate form for providing services on the Service or in the mobile app, or provides Personal Data in another form, and until the termination of the relationship between Kroog and the User as a result of deleting his account, or withdrawing consent to the processing of Personal Data by the person who provided such data in another form.

Our Service may contain links to third party Services. When you click on a link to any other Service or location, you will leave our Service or Services and go to another Service, and another entity may collect personal information or anonymous data from you. We have no control over, do not review, and are not responsible for, these outside Services or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside Services or content, or to any collection of your personal information after you click on links to such outside Services. We encourage you to read the privacy policies of every Service you visit. The links to third party Services or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or Services.

Kroog shall not sell or lease Personal Data to third parties for marketing purposes without obtaining the User's permission on a preliminarily basis.

Access to Users' Personal Data shall be possible within Kroog and its employees.

Kroog shall make every reasonable effort to ensure that:
* confidential information about Users is collected by Kroog only to the minimum extent necessary;
* confidential information is used exclusively for the purposes stated when it is collected;
* confidential information is not transferred to third parties, except as specified herein or applicable law.

Kroog shall store Personal Data and protect It from unauthorized access and distribution in accordance with internal rules and regulations. The User's Personal Data shall be kept confidential, except for cases when the Service technology or the software settings used by the User provide for an open exchange of information with other Users of the Service or with any Internet Users.

The User's Personal Data shall be kept confidential, except for cases when the User voluntarily provides information about himself for general access to an unlimited number of persons.

Kroog ensures the confidentiality and security of Personal Data when processing it in accordance with the requirements of applicable law. Kroog shall apply appropriate technological and operational security standards to protect information provided by visitors to our Service from unauthorized access, disclosure, distortion or destruction.

After the above-mentioned period of storage of the User's Personal Data expires, the User's Personal Data shall be destroyed. Personal Data shall be destroyed by erasing information using certified software with guaranteed destruction (in accordance with the specified characteristics for the installed software with guaranteed destruction).

The User's Personal Data shall be kept by Kroog exclusively on electronic media and processed using automated systems, except for cases when non-automated processing of Personal Data is necessary in connection with the implementation of the requirements of the applicable law.

User Generated Content: The User agrees that images placed by him within the service can be used by Kroog on other Kroog services and resources, as well as in advertising or marketing materials posted on Kroog resources on the Internet to attract the attention of other Users to the Service or to other Kroog resources and services, both with stating their author (the author's name will be specified as the name of the User, which he specified during registration), and without it, without the need to obtain special User's permission and without paying royalties. If the User does not have the right to grant Kroog the right to use any image in the specified ways, he shall refrain from downloading such an image.

The User understands and does not object to the fact that Kroog is an international company operating in many countries of the world. The transfer of information outside the User's country and its subsequent protection shall be carried out in accordance with this Provision, as well as applicable law.

USER'S RIGHT

The User can at any time change (update, supplement) the Personal Data provided by him or part of it, as well as the parameters of its privacy, using the function of editing Personal Data in the personal account.

The User shall be entitled to withdraw the consent to the processing of Personal Data at any time, subject to written notification to Kroog via the communication channels specified on the Service in the "Help" and "Contacts" section or by contacting Kroog as specified in section 7 below, at least 30 days before the expected date of termination of processing and use of the Personal Data provided.

FINAL PROVISIONS

This Policy shall apply only to the Service and Kroog. Kroog shall not control and not be responsible for the services and offers of third parties to which the User can click on links available from the services of the Service, including information about the User processed by third parties.

Choices

Kroog offers you choices regarding the collection, use, and sharing of your personal information. We may periodically send you emails that directly promote the use of our Services. When you receive promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the email you receive or by contacting us directly. Despite your indicated email preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.

Cookies: If you decide at any time that you no longer wish to accept cookies from our Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser's technical information. If you do not accept cookies, however, you may not be able to use all portions of the Services or all functionality of the Services. If you have any questions about how to disable or modify cookies, please contact us at data@kroog.io

The User shall be solely responsible for the security (resistance to selection) of the means chosen by him for accessing the account, and also independently ensure their confidentiality. The User shall be solely responsible for all actions (as well as their consequences) within or using the Service's functionality under the User's account, including cases where the User voluntarily transfers data for accessing the User's account to third parties on any terms (including under contracts or agreements). In this case, all actions within or using the services of the Service under the User's account shall be considered to be performed by the User himself.

The Service is not intended or not specifically intended for use by persons under the age of 18. The Policy shall not provide for the intentional collection or storage of Personal Data of persons under the age of 18.

HOW TO CONTACT US

If you have any questions about our Privacy Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us: through a link "Contact us" in the mobile app (Service); or by email: data@kroog.io where you can reach our Data Privacy Officer.

Our Company keeps its Privacy Policy under regular review and places any updates on this web page and mobile app. This privacy policy was last updated on 20 October 2020, v.1.0.

AUTHORITIES

Should you wish to report a complaint or if you feel that Our Company has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner's Office: Iasonos 1, 1082 Nicosia, Cyprus, commissionerdataprotection.gov.cy
Privacy Policy
License Agreement

© 2020-2021. Kroog, Inc.
124 Broadkill Rd #511, Milton DE 19968-1008

© 2020-2021. BRT Solutions Ltd.
Peiraios, 30, 1st Flat/Office 1, Strovolos, 2023, Nicosia, Cyprus