Purpose of the Policy: This Policy describes how sost (hereinafter also “us,” “we”) collects, uses, discloses and otherwise processes the personal data you provide by using the Coding Ninjas, Inc. website, located at https://sost.tech (the “Site”) or the services, rendered through the Site, or any other services of Coding Ninjas, Inc. (the “Service”).
Age Restriction: We require users of the Service to be at least 18 years of age. We do not intend for anyone under the age of 18 to use any of the features or services we offer from the Service and we do not knowingly collect personal data from anyone under the age of 18 – so, please, if you are under 18 do not use the Service. We understand and are committed to respecting the sensitive nature of people’s privacy online. If we find out or suspect you are less than 18 years old – we retain the right to limit, pause or cancel your use of the Service in the manner we may deem feet. If you suspect that a user is under the age of 18, please use the report profile mechanism available through the Service.
- PURPOSES OF PROCESSING
As used in this Policy, “personal data” is as defined in the General Data Protection Regulation 2018 and any successor legislation, which includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, email address. We need certain personal data in order to provide you with access to our Service. To process your personal data as outlined below, we rely on the following legal bases:
Contractual Performance: The primary reason we process your personal data is to perform the contract that you have with us by having your sost Account or using the Site as registered user. For example, as you use our Service, we use your personal data to provide your Account, to make it visible to other users and to make development contracts with Freelancers available for you to create and manage within your Account.
Legitimate Interests: We may also use your personal data where we have legitimate interests to do so. For instance, we review users’ actions while using our Service to improve our Service and we process personal data for administrative, fraud detection and other legal purposes.
Consent: We may also ask for your consent to use your personal data for specific reasons. You may withdraw your consent at any time by contacting us as set out at the end of this Policy.
- INFORMATION WE COLLECT AND HOW WE USE IT
In using the Service, you are required to provide personal data to verify that you are the specific person you say you are. This personal data can include first and last name, email or phone number. In order to create your sost Account (hereinafter – “Account”) as described in our Terms, you provide us with certain personal data, such as your name and email. After Account created and you receive access thereto, you are entitled to input and amend any information, including your personal data into your Account. In both cases you warrant that you (a) provide us with true, relevant and actual information, AND (b) have never committed a felony or indictable offense (or crime of similar severity), or any crime involving fraud, and you are not under any police control as an intellectual property fraudster.
We draw your attention that we do not intend to gather any personal data which may be considered “special” or “sensitive” in certain jurisdictions, for example, gender, age, religious and political views (“Sensitive Personal Data”).
We may collect and store information about you in connection with your use of the Service, including any information you transmit to or through the Service. We use and process that information to provide the Service’s functionality, fulfill your on-Site requests, improve the Service’s quality, engage in research and analysis relating to the Service, personalize your experience, track usage of the Service, market the Service, provide customer support, message you, back up our systems, allow for disaster recovery, enhance the security of the Service, help combat fraud and abuse, estimate and report total audience size and traffic, and comply with legal obligations. Even when we do not retain such information, it still must be transmitted to our servers initially and stored long enough to process.
Please also note:
1. Information collected automatically: When you use our Site, our servers automatically record your log data which is the information that your browser sends whenever you visit a website as well as your personal data. This data includes but is not limited to: device OS and version, device model (as well as unique device identifier), IP addresses, browser type, referral URL’s, language information, the domain from which you are visiting, Service signup date, last payment date, Deposit balance, and first subscription date, WiFi information such as SSID, advertising identifier, requested and referring URLs and additional information in respect to your usage and browsing of the Site. This personal data allows us to diagnose bugs as well as detect fraud. We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we use to show you local information. This personal data also allows us to send notifications.
2. Account Information: In order to create your sost Account and after that – during the whole period it exists, we may store and use the information you provide during that process, such as your name and other information you may provide with your Account, such as your name, the name of the business entity you represent, billing information. We may publicly display such information as part of your Account profile. You are entitled to create an Account of your own only and you are strictly forbidden to use any personal data of any other persons while creating your Account. If you believe that someone has created an unauthorized account depicting you or your experience, please, contact us at email@example.com immediately.
3. Public Content: No public content, which is not belonging to us, is intended for posting on the Site or through the Service.
4. Contacts: You can invite others to join sost (but not to create their sost Account anyway) by providing us with their contact information. We may transmit that information to our servers long enough to process your invitations and such contact information. Please note, that we may address such invited person with written notice using his / her contact data you provided to us and we will indicate that it was you who invited him/her to join sost and in the same time you bear sole responsibility for the lawfulness of our access to such third person personal data you provided.
5. Communications: When you sign up for a Service Account or use certain features, you are opting to receive messages from other Site users and us. You cannot opt out of receiving certain administrative, transactional, or legal messages from us. Please note that in case you opt out you may miss some important notification from us and hence you relieve us from any liability related to such notification delivery or non-delivery. We may also track your actions in response to the messages you receive from us or through the Service, such as whether you deleted, opened, or forwarded such messages. If you exchange messages with others through the Service, we may store them in order to process and deliver them and administrate the Services and render our mediation services, as well allow you to manage such messages, and we may review and disclose them in connection with investigations related to use of the Service, as well as our efforts to improve the Service. We may not deliver messages that we believe are objectionable, such as spam messages, fraudulent solicitations, or requests for some services, which can not be provided or requested through the Site. If you send or receive messages through the Service using cell (mobile) phone), we may log phone numbers, phone carriers, and the date and time that the messages were processed. We may also store information that you provide through communications to us, including from phone calls, letters, emails and other electronic messages, or in person. If you are a representative of a business entity, we may contact you, including by phone or email, using the contact information you provide us, which is made publicly available, or that we have on record for your business. Our calls with you may be monitored and recorded for quality purposes and with no additional notification.
- Processes– Intended to make the Service work in the way you expect. For example, we use a Cookie that tells us whether you have already signed up for an Account.
- Preferences– Intended to remember information about how you prefer the Site and Service to behave and look. For example, we use a Cookie that tells us whether you have declined to allow us to send push notifications to your phone.
- Notifications–Intended to allow or prevent notices of information or options that we think could improve your use of the Site. For example, we use a Cookie that stops us from showing you the signup notification if you have already seen it.
- Analytics– Intended to help us understand how visitors use the Site. For example, we use a Cookie that tells us how our search suggestions correlate to your interactions with the search page.
You can set some Cookie preferences through your device or browser settings, but doing so may affect the functionality of the Site. The method for disabling Cookies may vary by device and browser, but can usually be found in your device or browser preferences or security settings. For example, iOS and Android devices each have settings which are designed to limit forms of ad tracking. Please note that changing any of these settings does not prevent the display of certain advertisements to you.
- HOW WE SHARE YOUR INFORMATION
We may share your personal data with other Service users, with service providers and partners who help us operate the Service, in the event of a business transaction and for law enforcement purposes. Third parties may receive information about you as follows:
1. Service Providers: we may share your personal data with third parties to provide you with the Service (such as analytics services or customer relationship management services). We vet all service providers before we provide them with your personal data and ensure we have appropriate contractual safeguards in place.
2. Aggregate or Anonymous Information: We may share user information in the aggregate with third parties. For example, we may disclose the quantity of our users or their Contracts completed / in progress or any Account stories – for marketing or statistics purposes. We may also disclose anonymized information about your use of Service, for example, if you engage in a transaction in connection with Service, we may publicly disclose information about the transaction without providing identifying information about you or otherwise disclosing your participation in the transaction.
We drive your attention to the fact that sharing your information in no case selling, renting, releasing, disclosing, transferring or other communicating orally, in writing, by email or other means to any third party for monetary or other type of valuable consideration.
It is our sost’s policy not to use or share the personal information of Site users in ways unrelated to the ones described above without also providing you an opportunity to opt-out or otherwise prohibit such unrelated uses.
- CONTROLLING YOUR PERSONAL DATA AND YOUR RIGHTS
Below, we have outlined some of the tools you have to control your personal data.
Tools in the Service: The Service provides certain tools that allow you to access, rectify, delete or even cancel external use of information that you provided through the Service and that’s associated with you. Other users may be able to identify you or associate you with your account if you include personal information in the content you post publicly. Please also note that the messages you send or receive using the Service are only private to the extent that both you and the person you are communicating with keep them private. For example, if you send a message to another user, that user may choose to publicly post it. Also, we may access and disclose such messages in the course of investigations relating to the use of the Service.
You should also be aware of your privacy rights.
Reviewing your information: Applicable privacy laws may give you the right to review the personal data we maintain about you. To request access to your personal data, please contact us as set out at the end of this Policy.
Updating your information: If you think the information we hold about you is inaccurate or that we are not entitled to use it and would like to request that we rectify, delete or object to our processing of this personal data, please contact us as set out at the end of this Policy. You retain the whole responsibility for the accurateness and actuality of the information we hold about you.
Moving your information. Your data is portable – i.e. you have the flexibility to move your data to other service providers as you wish. To request this, please contact us as set out at the end of this Policy.
Accountability: Some countries, including those in the European Union, provide you with a right to file a complaint with the appropriate data protection authority if you have an issue with how we process your personal data.
For your protection, we may ask you to prove your identity before we answer any requests related to the above items. Note, that we may request additional information from you to verify your identity and even reject a request for certain reasons, including if it is unlawful or if fulfilling the request will infringe a trade secret or other intellectual property or the privacy of another user.
- THIRD-PARTY PAYMENT PROCESSOR
We use a third party payment processor to process payments made to us. In connection with the processing of such payments, we do not retain any personally identifiable information or any financial information such as, inter alia, credit card numbers. Rather, all such information is provided by you directly to our third party processor, Stripe. You can read more about their policies at: https://stripe.com/privacy.
We draw your attention to the fact, that if you initiate a transaction through the Service, such as a purchase, payment processor may collect and store information about you, such as your name, phone number, address, email, and payment information (such as a credit card number and expiration date), as well as any other information as the case may be, in order to process your transaction, send communications about them to you, and even populate forms for future transactions. This information may be shared with third parties for the payment operating and processing purposes.
In any case, we hereby encourage you to keep your payment information in strict confidence and not to share it with any persons (including other Service members, your children and relatives) except for with payment processors for the purpose of making purchase you independently have decided to make at your own discretion and will – so that any purchase you make through the Service is considered as made by you personally and willingly.
- DATA RETENTION AND ACCOUNT DELETION
If You decide to delete your Account on the Site You can ask us to delete it by notifying us at the contact information set out below.
For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Service or to comply with legal obligations. Please remember that even though our systems are designed to comply with the above retention periods, we cannot promise that 100% of the data will always be deleted on time due to technical constraints.
- CROSS-BORDER DATA TRANSFERS
The sharing of personal data as explained in this Policy may involve the transfer of personal data across border, for instance from the United States to other jurisdictions, where data protection and privacy regulations may not offer the same level of protection. As an opposite example, where the Service allows users to be located in the European Economic Area (“EEA”), their personal data is transferred to countries outside of the EEA. Your personal data we process is stored in the United States (“USA”) – in no case it means that it will be shared, as described herein, only within the territory of the USA. We use standard contract clauses recommended by the National Institute of Standards and Technology or another suitable safeguard to permit data transfers from the USA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.
We use various safeguards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet or via a mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
We may suspend your use of all or part of the Service without notice if we suspect or detect any breach of security. If you believe that your Account or personal data is no longer secure, please notify us immediately at the contact information set out below.
- SERVICE AREA BEYOND OUR CONTROL
Other users: The Service includes user-generated profiles and interactive messaging services. Please remember that any information that is disclosed in these areas may be seen and copied by other users and you should exercise caution when deciding to disclose your personal data. You remain the only liable for any your activities or posting any messages that may harm or abuse any third party in any manner; and from other side note that due to the specific nature of the Site some other Service users may post some content which can be abusing or inacceptable for you – we do not bear any liability for such content posting, but of course you may contact us with appropriate complaint for which we shall send you a proper answer with no warranty of your complaint settlement or solution.
Third-party websites: The Site, the Service (or any Contract created inside of it) may contain links to other websites. If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.
- HOW TO CONTACT US