Confidentiality policy

1. PURPOSE AND SCOPE

1.1. General provisions

“JOINT-STOCK COMPANY “INSURANCE COMPANY “INGO” (hereinafter referred to as the Company) understands the importance and responsibility of ensuring the confidentiality and integrity of personal data of individuals who use the Company’s services on the Company’s main website ingo.ua (hereinafter referred to as the Website) and other digital services (hereinafter referred to as the Service) of the Company: chatbots, mobile applications etc.

The User of the Website and/or Company’s Services (hereinafter referred to as the User) agrees to this confidentiality policy (hereinafter referred to as the Policy), which defines the rules for the Company’s receipt, storage, processing, use and disclosure of Users’ personal data.

The User is not entitled to use Company’s Website and other Services in case of disagreement with the terms of this policy.

A link to the Policy is available on the main page of Website and Services provided by the Company to Users.

1.2 Definitions and Abbreviations

Service – any digital service of the Company (websites, chatbots, mobile applications etc.) that provides Users with services for receiving advertising and information materials, insurance products,
terms of concluding insurance contracts etc.

User – an individual who uses Company’s Website and its other Services (chatbots, accounts, mobile applications, etc.). The User is the subject of personal data.
Personal Data – information (information or a set of information) about the User that allows him to be identified as an individual.

Account – a set of information about the User that contains the user’s authorization data (login and password or other authentication parameters, for example, pin code, biometrics) necessary to identify the user when using Company’s Website and other Services.

Cookie – a piece of data (usually a small text file) created by the Website (or other Company’s Services) and stored on the user's computer in the form of one or more files. Cookies are intended to store the User's preferences and do not contain personal data and can be rejected by the User at any time at his/her request.

2. USER CONSENT

In accordance with the provisions of the law of Ukraine "On Personal Data Protection" (hereinafter referred to as the Law), the Company is the controller and processes the Users' personal data when providing and ensuring insurance services, using the services on the basis of a permission to process personal data provided in accordance with the law for the exercise of powers and for the performance of a transaction to which the user is a party.

The User provides unconditional, unlimited consent to the processing of his personal data for the purpose of: familiarization with the Contractual Documentation (General Terms and Conditions of the insurance product, information on the standard insurance product, information sheet on the standard insurance product, information on the insurer, information on the intermediary), conclusion and execution of insurance contract by the company, receipt of advertising and information materials about insurance products and services.
By registering on the Company's official website, in mobile applications, application program interfaces and applications, the User confirms that he is familiar with the terms of this Confidentiality Policy, in particular for the purpose of processing personal data specified in this Policy and the rights granted to personal data subjects in accordance with Article 8 of the Law, and the use of personal data by the Company, by checking the box "I agree with the Confidentiality Policy".

3. POLICY

3.1 General Provisions

The Policy is aimed at publicly informing Users about the procedure for collecting (processing), storing and transferring their personal data, which is provided while providing Company’s Website and other Services.

3.2 Purpose of collecting and processing personal data

The purpose of processing is to provide Company’s Website and other Services (chat bots, mobile applications etc.) with the necessary services to Users: obtaining information about insurance products, conditions for concluding insurance contracts etc.

The information received by the Company is used for:

Concluding and executing insurance contracts in accordance with the requirements of the legislation of Ukraine.
Creating a user account.
Providing services or a function ordered by the User.
Communicating with Users to inform about Company’s personalized unique offers and campaigns.
Evaluation and analysis of the market, customers, products and services provided by the Company.
Effective customer service.
Providing updates and technical support for the Services, including the mobile application on the User's device.
Any other purposes in the amount sufficient for the high-quality provision of insurance services to the user through the services.

3.3 Rules for collecting and processing personal data, authorities and obligations of the Company and User

The Company ensures the storage of information with limited access and Personal Data of Users, is responsible for their disclosure under the current legislation of Ukraine.

Users are responsible for accepting the terms of this Policy when using Company’s Website and other Services.

The User has the right to receive information about the procedure for processing their personal data, as well as other rights specified in part 2 of article 8 of the Law of Ukraine "On Personal Data Protection" (hereinafter referred to as the Law).

The User undertakes, in particular, but not limited to:

not to commit actions aimed at misleading other Users and Company.
not to provide their personal data for use by third parties.
not to collect, systematize, store, process or distribute personal information of other Users.
not to attempt to gain access to personal data of other Users by any means, including, but not limited to, through fraud, abuse of trust, selection of authentication and identification data.

If the User registers on the Company’s official website and/or Services in the interests of third parties, in this case, by providing this consent, the User confirms that he has sufficient authority to perform such actions, including - to provide consent on their behalf to the processing of personal data on the terms set out above, as their representative (father, mother, guardian and other persons provided for by the legislation of Ukraine).

The Company undertakes not to provide Personal Data to third parties without consent of the User to whom this data belongs, except for cases of disclosure established by the current legislation of Ukraine. The transfer of Personal Data to third parties is allowed in the following cases:

After obtaining consent of the User to whom this information belongs.
If it is necessary to transfer the Personal Data in order to fulfill User’s order or request and/or to involve third parties for such fulfillment.
Upon reasonable requests of state bodies entitled to receive such data.
If according to the Company, the User violates the terms of this Policy and/or other contracts and agreements between the Company and User.

The User allows the Company to grant permission to other companies with which the Company has concluded relevant agreements to receive, store and process data about the User (except for Personal Data), such as User's IP address, Cookie files as well as statistical information about User's activity to improve the quality of services and advertising information provided by these companies.

The Company may transfer information received from Users when providing the Services to third parties in order to properly fulfill its obligations under these Services.

The Company may distribute personal data without consent of the User or its authorized person in cases specified by the legislation of Ukraine, and only (if necessary) in the interests of national security and human rights.

Cookies that may be used by the Company do not contain Personal Data and cannot harm the User's devices. Most Cookies that may be used by the Company are so-called session cookies, which are automatically deleted at the end of User's visit to Company's Website and Services. Other Cookies remain on the User's devices until he deletes them. These Cookies allow the User's web browser to be recognized during the next visit.

The User agrees that the confidentiality of data transmitted via the Internet is not guaranteed and if access to this data is obtained by third parties outside the area of Company's technical means of ensuring communication security, the Company is not liable for damage caused by such unauthorized access.

The User has the right to request, change or delete his/her Personal Data that is in the Company's access. To do this, the User must make a corresponding request by sending it to the Company's contact address specified on the Website, unless another independent method of requesting, changing or deleting Personal Data is provided by the technical capabilities of Company's Website and/or Services.

Personal Data is stored on the Company's internal resources, access to which is limited in accordance with the requirements of company's information security policy, the Company's regulations on the protection of trade secrets and other internal policies and procedures of the Company on the information security.

Sufficient measures to protect information have been taken on the Company's web resources, however, it must be taken into account that there is no absolutely safe and error-free way of transmitting data over the Internet.

The Company is not responsible for the functioning of servers, internet access service providers, the work of third parties, due to whose fault access to the Website may be impossible or limited, possible information leakage due to the fault of third parties, as well as for the user's disclosure of their personal data, including authorization data on the company's website, in mobile devices, application program interfaces and applications.

The information posted on the Сompany's web resources is protected by the current legislation of Ukraine, which regulates intellectual property rights. Reproduction, translation, archiving, copying to other electronic media of the information posted is prohibited.

Some services of the Website and Services provide for the user to make and/or receive payments using third-party payment systems that are not subject to the Company and have their own terms of use and confidentiality policy.

3.4 Additional information

The Company reserves the right to amend the Confidentiality Policy. All amendments made to the Agreement will be available in new version of the Policy, at the link https://ingo.ua/en/privacy-policy .

In case of significant amendments to the Policy, the Company will additionally notify the User (if necessary) of these amendments by e-mail specified in User's account and/or by publishing on the Company's own website.

All amendments to the Policy come into force from their publication. By using the Website or Services, the User confirms his consent to the new terms of the Policy in the version in force at the time of User's use of Company’s Website and/or Services.

The Company is not liable for any harm or losses suffered by the User or third parties as a result of misunderstanding of the terms of this Policy, instructions or guidelines on the procedure for using the Website and/or Services, regarding the procedure for posting data and other technical issues. Until the acceptance of the terms of this Policy, any User has the right to contact the Company for clarification of the provisions of the Policy.

In case of recognition of any part of this Policy as invalid or unenforceable, other parts of the Policy remain in force. The waiver of any provision or condition of this Policy by each of the Parties (the User and Company), or any violation thereof, does not cancel his provision or condition.

This Policy and Relations between the Company and User arising in connection with the Use of the Website and/or Services are governed by the current legislation of Ukraine. Each party expressly agrees that the relevant courts of Ukraine shall have exclusive jurisdiction over any claims, disputes or disagreements relating to the Policy and the use of Website and/or Services.

If you have any questions regarding the Confidentiality Policy, please send an email to office@ingo.ua