POVODOG MOBILE APPLICATION PRIVACY POLICY

1. DEFINITION OF CONCEPTS

 "Law" means the Law of Montenegro, as well as other legislative acts of Montenegro.

"Mobile Application" is software (with all existing additions and improvements) designed to run on smartphones, tablets, watches and other mobile devices, and developed for a specific platform (iOS, Android). For the purposes of this Policy, the Mobile Application means the following software: "POVODOG" mobile Application.

"Personal data" means a set of personal data and / or non-personalized information about the User provided by him to the Right Holder and / or automatically collected by the Right Holder and / or third parties.

"Policy" means this Mobile Application Privacy Policy (with all existing additions and changes).

"User" means a legal entity or individual who downloaded the Mobile Application on a smartphone or any other mobile device and / or activated such Mobile Application on one of the specified devices.

"User Agreement" means an agreement concluded between the Right Holder and the User regarding the procedure, rules and features of the User's use of the Mobile Application. The user joins such an agreement and does not have the right to make and / or demand the introduction of any changes or additions to it. The user can familiarize himself with the terms of the User Agreement at the following link: https://povo.dog/media/files/en/terms_and_conditions.html.

"Right Holder" means the following person who owns the exclusive rights to own the Mobile Applicatio:

Lebedeva Arina Sergeevna, location address: 85340, Montenegro, Herceg Novi, Kumbor bb (including its branches and representative offices both on the territory of Montenegro and abroad, as well as any other persons created as a result of the reorganization of the Company)

"Cookies" means small files sent by any mobile Applications or site and placed on smartphones and other mobile devices of the User to improve the operation of such Applications or sites, as well as the quality of the content posted in them.

2. RELATIONS TO WHICH THE POLICY APPLIES

 General Provisions

This Policy is used and applies exclusively to Personal data received from the User in connection with his use of the Mobile Application. The provisions of this Policy are aimed at:

(1) determination of the types and types of received Personal data, directions and purposes of use (processing) of Personal data, as well as sources of obtaining such Personal data; and

(2) determination of the User's rights in relation to the protection of the confidentiality of the Personal data transmitted by him; and

(3) determination of the persons responsible for the processing and storage of Personal Data, as well as third parties to whom such data is disclosed (in whole or in part).

The rules of this Policy do not apply in the case of processing by third parties of Personal data that are voluntarily provided by the User.

By installing and / or activating the Mobile Application on a smartphone or other mobile device, the User agrees to the terms of this Policy and gives his consent to the Right Holder for the collection, processing, retention and storage of Personal Data in the manner and under the conditions stipulated by this Policy.

If the User does not agree with the terms of the Policy and / or certain conditions of the Policy are not clear to him, in this case, the User is obliged to immediately stop using the Mobile Application.

User rights to protect personal data

In connection with the provision of personal data, the User automatically receives the following rights:

(1) receive data concerning their processing (the grounds and purposes of such processing, the processing methods used, information about the persons who have access to them or to whom they may be disclosed on the basis of an agreement or the Law).

(2) receive data on the location and identification data of persons who process Personal Data.

(3) receive data on the storage periods of Personal Data.

(4) receive data on the performed or expected cross-border transfer of Personal Data.

(5) to appeal against the actions or inaction of the Right Holder to the authorized body for the protection of the rights of subjects of personal data or in court.

(6) receive compensation for losses and / or compensation for moral damage in court as a result of violations of the User's rights to the protection and protection of his Personal data committed by the Right Holder and / or third parties.

(7) exercise other rights in the field of personal data protection provided for by the Law or the provisions of this Policy.

3. LIST OF COLLECTED PERSONAL DATA

 Non-personalized information about Users

In connection with the use of the Mobile Application, the Right Holder may automatically collect and process the following non-personalized information about the User:

(1) information about traffic, the possible number of clicks, logs and other data.

(2) information about the location of the User (geolocation). The user can turn off geolocation at any time by changing the settings of the device from which the Mobile Application is entered.

(3) information about the device (identification number, network of the mobile operator) from which you log in, operating system, platform, browser type and other information about the browser, IP address.

Personal data about Users

The User provides the Rightholder about himself with the following personal data:

(1) name or name for the Shelter

(2) nickname

(3) date of birth

(4) gender

(5) email address

(6) mobile phone number

(7) address of orders for walking

(8) website

(9) a photograph showing the User or the Shelter

(10) TIN of the organization for legal entities

(11) constituent documents for legal entities

(12) data from the following social network: Vkontakte, Google, Facebook. The Right Holder can collect, process and store the User ID of any of the social networks that was used by the User within the Mobile Application. If the registration of the User in the Mobile Application is carried out using one of his accounts on social networks, the User thereby provides the Right Holder with automatic consent to the collection, processing and storage of Personal Data that have become available to the Right Holder through the selected social network.

(13) data contained in the personal account (profile) of the User, all internal correspondence of the User (if any), as well as other activity of the personal account (profile) of the User.

(14) data on orders / purchases made to Users and / or received / paid services through the Mobile Application.

(15) data on all publications made by the User in the Mobile Application, including, but not limited to, comments, ratings, reviews, publication of reports and photos, likes, ratings and / or any other forms of activity available to the User in the Mobile Application , and / or generated content.

(16) data and information obtained as a result of combining certain Personal data of a specific User, as well as data and information received from third parties (partners, marketers, researchers).

The user is the only person responsible for the completeness of the provided personal (personal) data and is obliged to timely change them (update, check, correct) on a regular basis.

The Right Holder assumes that all personal (personal) data provided by the User are reliable, and that the User maintains such information up to date.

4. PURPOSES OF COLLECTING AND PROCESSING PERSONAL DATA

 Determination of the purposes of processing

The collection and processing of Personal Data is carried out for the following purposes:

(1) to analyze the behavior of the User, as well as to identify the User's preferences for a certain type of content.

(2) for the efficient and correct operation of the Mobile Application, improving the functioning of the Mobile Application, improving the content of the Mobile Application, improving the internal architecture and functionality of the Mobile Application.

(3) to identify the User.

(4) to provide personalized advertising and marketing materials.

(5) to send personalized advertising and marketing materials to the specified email address and / or mobile phone of the User.

(6) to comply with the requirements of the Law.

(7) to track orders / purchases made by the User through the Mobile Application.

(8) to determine the location of the User.

(9) for technical support of the Mobile Application, identification of problems in its operation and their elimination.

(10) to keep in touch with the User (communication).

(11) to fulfill other obligations of the Right Holder that arose before the User.

(12) for statistical research.

(13) for any other purpose, subject to obtaining a separate consent from the User.

The processing of Personal Data is carried out on the basis of the principles: (1) the legality of the purposes and methods of processing; and (2) good faith; and (3) compliance of the purposes of processing Personal Data with the purposes predetermined and declared in the collection of such Personal Data; and (4) the extent and nature of the processed Personal Data is consistent with the stated purposes of their processing.

Personal data processing conditions

Personal data processing is carried out in the following cases: (1) obtaining consent from the User; or (2) achievement by the Right Holder of the goals stipulated by an international treaty or the Law; or (3) the User provides his Personal Data to an unlimited number of persons; or (4) fulfill other obligations of the Right Holder to the User, including, but not limited to, the provision of certain content to the User; or (5) saving the life or health of the User, when consent to the processing of his Personal Data cannot be obtained in advance.

In the case of anonymization of Personal Data, which does not directly or indirectly determine the User, the subsequent use and disclosure of such data to third parties is allowed and the rules of this Policy no longer apply to them.

The Right Holder takes all possible measures to protect the confidentiality of the received Personal Data, except for cases when the User has made such data publicly available.

The processing of Personal Data is carried out using automation tools and without using such automation tools.

5. ACCESS OF THIRD PARTIES TO PERSONAL DATA

 Use of remarketing services

The Right Holder uses remarketing to advertise the content of the Mobile Application to the User on other sites visited by the User.

Remarketing services are provided to the Right Holder through the platforms Google ads, Facebook, Yandex. Google Ads, Facebook, Yandex collect and process non-personalized data that do not directly allow the user to be identified or identified. The information collected can typically include (1) the content that the User viewed, (2) the date and time the User viewed the content, (3) geolocation data. The collection and processing of such non-personalized information allows us to provide the User with more targeted advertising or marketing content.

By installing the Mobile Application, the User agrees with the Privacy Policy of the specified marketing service providers and their User Agreements, as well as with the automatic installation of the corresponding Cookies on the User's device.

The User has the right to refuse such advertising at any time by changing the corresponding settings of the browser and the device from which the Mobile Application is logged in.

Disclosure of personal data to third parties

The Right Holder has the right to disclose Personal Data (1) to its affiliates, branches and representative offices open both in the territory of Montenegro and in the territory of other states; (2) the legal successors of the Right Holder who arose as a result of its liquidation, reorganization or bankruptcy, and who received exclusive rights to own the Mobile Application; (3) payment service providers or banking (financial) institutions to conduct User's transactions through the Mobile Application; (4) to third parties solely for the purpose of providing the User with certain content or access to it; (5) to third parties, when the User has given consent to the disclosure, transfer or processing of his Personal Data, as well as in other cases expressly provided for by the Law or this Policy.

The Right Holder discloses Personal Data only if (1) is sure that third parties will comply with the terms of this Policy and take the same measures to protect the confidentiality of Personal Data that the Right Holder himself takes, and (2) consent to such disclosure has been previously expressed User and / or allowed by law.

Advertising from third parties

The Mobile Application content may contain advertising banners and / or links to third-party websites. The User's use of such sites (by clicking on a link or in any other way) may entail the collection, processing and use of Personal Data, as well as the possible automatic transfer of Cookies to the User's device, from which the transition to the site of third parties is made. The Right holder does not bear any responsibility for the methods, methods and procedure for the processing of Personal Data by third-party websites. As a result, the Right Holder is also not a responsible person in the event of disclosing Personal Data to an unlimited number of persons in connection with the User's use of such sites.

The Rightholder strongly recommends that each User familiarize himself in detail with the personal data protection policies of the sites used.

6. PLACEMENT OF ADVERTISING

 Advertising in a mobile application

The Right holder, along with the content, places in the Mobile Application various advertising and marketing materials, taking into account the revealed preferences of the User to this or that content. The placement of advertisements in the Mobile Application presupposes the installation of certain Cookies on the device.

7. SENDING COMPLAINTS AND REQUESTS TO THE RIGHT HOLDER

 Request to terminate the processing of personal data

Each User has the right to express his objection to the Right Holder against the processing and / or storage of his Personal Data. Such an objection may be expressed as follows:

in the User profile, go to the section: Contact technical support. Fill out the feedback form.

Request for information about personal data

If the User has questions related to the procedure for applying or using this Policy, the procedure and / or method of processing Personal Data, the User can ask such a question as follows:

in the User profile, go to the section: Contact technical support. Fill out the feedback form.

Change (update, addition, correction) or deletion of personal data

The User has the right at any time to independently change his/her Personal Data or send a request to delete his/her Personal Data, unless such change or deletion may lead to (1) a violation of the rules of this Policy; or (2) a violation of the Law; (3) the nature of such Personal Data is evidence in any legal process that arose between the Right Holder and the User. To do this, the User needs to delete his personal account (profile) in the Mobile Application.

The Right Holder has the right to delete the User's personal account / profile at any time, as well as all Personal Data about the User if he has violated the terms of this Policy and / or the User Agreement.

In case of deletion of Personal Data about the User, all publications made by such User (comments, ratings, reviews, publication of reports and photos, likes, ratings) and / or any other forms of activity available to the User in the Mobile Application are also subject to automatic deletion.

8. TERMS AND PROCEDURE OF STORAGE OF PERSONAL DATA

 Storage is carried out independently by the Right Holder.

Storage is carried out during the entire lifetime of this Mobile Application.

The Right Holder undertakes to destroy or depersonalize his Personal Data after the personal appeal of the User of the Mobile Application. Such appeal can be expressed as follows:

in the User profile, go to the section: Contact technical support. Fill out the feedback form.

9. MINOR ACCESS TO THE MOBILE APPLICATION

 The Mobile Application can be used by persons under the age of 18.

The Mobile Application collects personal data about Users, therefore the use of this Application by minor Users is allowed only subject to prior consent from the legal representative (guardian) to process Personal Data.

If a minor User cannot consent to the processing of his Personal data from a legal representative (guardian), in this case such User is obliged to immediately stop using the Mobile Application.

10. PROCEDURE FOR PROTECTING PERSONAL DATA

 Protecting the confidentiality of Personal data is the primary and important task for the Right Holder. The Right Holder adheres to all required international standards, rules and recommendations for the protection of Personal Data.

The Right Holder has introduced a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access to them by third parties.

11. FINAL PROVISIONS

 Availability of Policy Text for Review

Users can read the terms of this Policy at the following link:

https://povo.dog/media/files/en/privacy_policy.html

This version of the Policy is valid as of November 6, 2023.

Changes and additions to the policy

This Policy is subject to change from time to time. The Right Holder does not bear any responsibility to the User for changing the terms of this Policy without the permission and / or consent of the User.

The user himself undertakes to regularly check the provisions of this Policy for possible changes or additions. However, in the event of a significant change in the terms of this Policy, the Right Holder undertakes to notify Users in the following way:

by sending a push notification.

Applicable legislation

This Policy has been developed in accordance with the current legislation on the protection of personal data of Montenegro.

Disclosure risk

Regardless of the measures taken by the Right Holder to protect the confidentiality of the personal data received, the User is hereby considered to be duly aware that any transfer of Personal Data on the Internet cannot be guaranteed safe, and therefore the User carries out such transfer at his own risk.

Public information

Within the Mobile Application, the User has the right to publish and post any content at his own discretion and in any of the available forms (photo, phone number, comment, rating, etc.). Such publications and content are publicly available to other Users of the Mobile Application, in connection with which the Right Holder does not assume any obligations to protect Personal Data that may be disclosed or published as part of such publication and / or content.