This Privacy Policy (hereinafter the “Policy”) describes how UAB Kuna Pro (hereinafter the “Company” or “We”) collects, uses, shares, and stores personal information of users of its Platform KUNA Car.

‍

This Policywas prepared in accordance with General Data Protection Regulation, Republic of Lithuania Law on Legal Protection of Personal Data and other applicable data protection legislation.

‍

We only collect the minimum amount of personal information needed to deliver our services to you. We take precautions to keep your data safe and secure. We will never sell or share your personal information with third parties without your consent, except as required by law.Please review the Policy carefully. If you do not agree with how your personal information will be collected and used as stated, we ask that you refrain from visiting our Platform.By using our Platform, you accept the terms of this Policy, our Terms of Use and other policies, and you consent to our collection, use, disclosure, and retention of your information as described in this Policy.We may make periodic changes to the Policy and will notify you of any updates. Should any conflict arise between the English language version of this Policy and any translation thereof, the English language version will prevail.The terms in this Policy are used in accordance with the Terms of Use and other applicable data protection legislation.

Contact Us:
All feedback, comments, requests for technical support, and other communications relating to the Privacy Policy should be directed to us by sending a letter to our email: hello@kunacar.com

‍

1. What Personal Data Kuna Cars Collects About You

Personal data means any information 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.

‍

Personal data does not include a person's name, title, business address or telephone number, as an employee of an organization. Where this Policy states that a list of items is "including", the lists so described are meant to be examples and not exhaustive or exclusive.

‍

1.1. Information You Provide Directly

The types of personal information we collect depend on how you interact with our Platform. We ask for limited information from you that is necessary to provide our services. Here are the categories of personal data we may collect:

‍

• Identity data: first name, last name, date of birth, gender, nationality, visual image of your face.
• Documents: national identity cards, passports, driving licenses or other forms of identification documents and tax ID number.
• Contact data: home address, work address, email address, phone number.
• Data regarding your transactions through use of the Platform: wallet address, purchased and booked cars, shipping preferences.
• Correspondence: chat messages with Company's Customer Support, chat attachments which may include screenshots, photos, videos etc., survey responses.

Please note, if you choose not to share certain information with us, we may not be able to serve you as effectively or offer you our services. As we add new features and services, you may be asked to provide additional information.

‍

2.2. Information we collect from you automatically

To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with our Platform. This information helps us to improve our Platform, and tailor content, recommendations, and advertisements we and third parties display to you. Information collected automatically includes:

‍

• Platform Usage Data: information about how you use the Platform, and other offerings made available by us, including:
• device download time,
• install time,
• interaction type and time,
• event time, name and source.
• Marketing data: your preferences in receiving marketing from us or third parties.
• Online Identifiers: geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.
• Buttons, tools, and content from other companies: The Platform may include links or buttons to third-party services, we may collect information about your use of these features.
• Cookies and Similar Tracking Technologies: We use cookies and similar technologies to provide functionality, such as storing your settings, and to recognize you as you use our Platform. In addition, we use cookies to gather information to provide interest-based advertising which is tailored to you based on your online activity. Please review our Cookie Policy to learn about our practices and the controls we provide you.

We may also automatically receive and record the following information on our server logs:

‍

• how you came to our Platform and use the services;
• device type and unique device identification numbers;
• device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
• how your device interacts with our Platform, including pages accessed and links clicked;
• broad geographic location (e.g. country or city-level location); and
• other technical data collected through pixel tags and other similar technologies that uniquely identify your browser.

2.3. Information We Get From Others

We may get information about you from other third party sources and we may add this to information we get from your use of the Platform. We may collect Personal Data from other parties in the following ways:

‍

Vendors and Partners: we may receive information about you from third-parties such as merchants, partners, or affiliates.

‍

Likewise, our marketing and support teams may receive access to third-party databases containing information to enrich business contacts and other corporate data.

‍

Other users of the Platform: other users of the Platform may provide information about you when they participate in chat with our support team.

‍

Public information: we may receive publicly available information on the internet about you.

‍

Public blockchain: we may receive information about you through monitoring your wallet address on publicly accessible resources.

‍

3. What Personal Data Company do not collects

We do not request or intentionally collect any sensitive personal data about Platform users without their consent. Sensitive personal data refers to personal information relating to your racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, health data, sex life, or sexual orientation.

‍

If you choose to voluntarily submit any sensitive personal data to us for any reason, you are solely responsible for ensuring you have the legal right to provide this information.

‍

We do not knowingly collect or process personal data from or with respect to persons under the age of 18, and you must be 18 years of age or older in order to use our Platform. If you are a parent or legal guardian and believe that your child under the age of 18 has submitted his or her personal data or other data without your consent, permission, or authorization – please let us know immediately, and we will promptly act to remove your child’s data from our database, cease the use of such data and inform any other party we suspect to have access to such data to do the same.

‍

4. Purpose of Processing Personal Data

We will process your personal data only for the purposes of providing the services you request, complying with legal obligations, and for our legitimate business interests such as improving our Platform and its security. If you are located in the EU, our processing of your data for legitimate interests will comply with Article 6 of the General Data Protection Regulation.

We will use your personal data for the following purposes:

• to manage risk and crime prevention including performing anti-money laundering, counter terrorism, sanction screening, fraud and other background checks, detect, investigate, report and prevent financial crime in broad sense, obey laws and regulations which apply to us and response to complaints and resolving them;
• to process and deliver our services to you, contacting you via email or calls, etc.;
• to provide our merchants or partners with the information required to complete your orders or booking requests.
• to provide our payment provider affiliates with all necessary information, required to complete a transaction;
• to keep our records updated and to study how customers use our products/services;
• to gather market data for studying customers' behavior including their preference, interest and how they use our products/services, determining our marketing campaigns and growing our business.
• to deliver relevant content and advertisements to you. You can opt out of marketing and mailing by sending a letter to our email: hello@kunacar.com
• to improve our Platform;
• or any purpose that you provide your consent.

We will not sell, exchange, transfer or give your personal information to any third party without your consent, except to provide services you request or support our operations. We may share information with third party service providers we use to deliver our services, who are obligated to keep your information secure.

‍

5. Sharing of Personal Information

We do not share the personal information that you provide us with other organizations without your express consent, except as described in this Policy. We disclose personal information to third parties under the following circumstances:

‍

Affiliates: we may disclose your personal information to our subsidiaries and corporate affiliates (i.e. our family of companies that are related by common ownership or control) for purposes consistent with this Privacy Policy.

‍

Business Transfers: we may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

‍

Merchants and Partners: we may disclose your personal information to our merchants and partners for purposes consistent with this Policy.

‍

Compliance with Laws and Law Enforcement, Protection and Safety: we may share personal information for legal, protection, and safety purposes.

‍

• We may share information to comply with laws.
• We may share information to respond to lawful requests and legal processes.
• We may share information to protect the rights and property of the Company, our merchants, customers, and others.
• We may share information in an emergency: this includes protecting the safety of our employees and merchants, our customers, or any person.

Professional Advisors and Service Providers: we may share information with those who need it to do work for us. These recipients may include third party companies and individuals to administer and provide the services on our behalf (such payment providers, customer support, hosting, email delivery and database management services, identity verification services), as well as lawyers, bankers, auditors, and insurers.

‍

Our Platform may contain links to other websites operated by third parties such as partners, advertisers, and payment processors. These third party sites have their own privacy policies which we do not control. We are not responsible for the content or privacy practices of any linked sites.

‍

If you click on a third party link, we recommend you review their privacy policy before submitting any personal information. We do not accept liability for the privacy practices or policies of third party websites. Please exercise caution and consult the privacy policies applicable to the site in question.

‍

6.  International Transfer

Our contractors and affiliates are situated at different locations and we sometimes need to transfer your personal data to third countries to provide our services to you.

‍

UAB "KUNA Pro" may transfer your personal data only in the following cases:

• if the country where we transfer your personal data provides an adequate level of personal data protection (based on the relevant decision of European Commission);
• if we take appropriate safeguards to ensure that your rights as a data subject are protected;
• if any derogations for specific situations apply (for instance, if such transfer is necessary for the establishment, exercise or defense of legal claims or for an important reason of public interest).

7. Data Subject Rights

You have the right to access, correct, restrict or delete your Personal Data, and to port your Personal Data to another company. While these rights may vary by jurisdiction, We provide you with the same rights and choices, no matter where you live. We provide these rights free of charge unless your requests are manifestly unfounded and excessive.

‍

You may exercise your choices and rights as follows:

• you can opt out of marketing and mailing by sending a letter to our email: hello@kunacar.com;
• you may receive a copy of personal data you directly volunteer to us in a structured, commonly used and machine-readable format;
• receive confirmation as to whether or not personal data concerning you is being processed, and access your stored personal data, together with supplementary information;
• request rectification of your personal data that is in our control;
• request erasure of your personal data;
• object to the processing of personal data by us;
• request to restrict processing of your personal data by us;
• lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. If you wish to exercise any of the aforementioned rights or receive more information, please contact us at hello@kunacar.com

‍

Please note that we may request that you provide some details necessary to verify your identity when you request to exercise a legal right regarding your personal data.

‍

8. Legal Basis for the Processing of your Personal Data

When our processing is subject to international laws, including but not limited to the General Data Protection Regulation that governs individuals located in the European Economic Area , we collect and process your personal data using one or more of the following legal bases set out by applicable law:

Performance of a contract: ****we use your personal data to complete and administer the contract you have entered into with GitLab, which includes the Terms of Use, and any other agreements and documents of our Platform.

‍

Legitimate Interests: we use your personal data for our legitimate interests, such as to provide you with relevant content, communicate with business leads, improve our products and services, and for administrative, security, fraud prevention and legal purposes. You may object to the processing of your personal data for these purposes at any time.

‍

Consent: we may use your personal data, with your consent, for specific purposes such as marketing, surveys, call recordings, and research.

‍

Compliance with a Legal Obligation: we may use your Personal Data in connection with legal claims, regulatory compliance, and audits.

‍

9. Security of Personal Data

Data security is of great importance to us, and to protect your personal data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Platform. Steps we take to secure and protect your data include:

• the pseudonymization and TLS 1.2 encryption of personal data;
• 2FA;
• the access control;
• the ability to ensure the ongoing confidentiality, integrity, availability and resilience of our processing systems and services;
• the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
• only authorized personnel of the Company have access to your personal data, and this personnel is required to treat the information as confidential.

While we implement appropriate security measures to protect your personal data, no method of transmission over the internet is certainly secure. We cannot guarantee absolute security of information transmitted to us online.

‍

Once received, we use strict physical, electronic, and procedural safeguards to protect your personal data against unauthorized access or disclosure. However, regardless of our efforts, no internet-based site cannot be guaranteed to be secure. We encourage you to take precautions when submitting personal information online. You may wish to refrain from submitting sensitive information if you have concerns.

‍

10. Data Retention

We retain personal data only as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, regulatory, or other compliance requirements. This may extend beyond the end of your relationship with us.

‍

We may retain certain information as required by law or for legitimate business purposes, such as preventing fraud, enhancing site security, or performing analytics on aggregated, anonymized data.

‍

For compliance with legal/regulatory obligations and industry standards, we may store records for the duration of our relationship with you and 5 years after. You consent to us retaining the necessary data for these purposes.

‍

11. Changes to Privacy Policy

We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email. If you do not accept a new edition of the Privacy Policy, you must stop using the Platform and services.

‍

If you previously used our Platform to book car services and we subsequently update this Privacy Policy in a way you do not accept, please contact us. Upon request, we will ensure car booking services you have already utilized, we will honor the Privacy Policy version that was in effect at the time of your booking.

‍

This allows you to reject any new Privacy Policy changes that materially impact the handling of your personal data for car bookings made before policy updates.