PRIVACY POLICY

This policy (referred to as “Policy” or “Privacy policy”) govern your relationship with the YOUPS website (the “Website”) and application (the “Application”) operated by Apace LTD. (“us“, “we“, “our“, “Company”, or “YOUPS”) and applies where we are acting as a data controller with respect to the personal data of our service users; in other words, where we determine the purposes and means of the processing of that personal data.

Apace LTD. is a corporation registered under the laws of Kazakhstan. These Terms refer to all websites that we own and operate, including the websites located at www.youps.io, and all related websites, our applications and/or APIs, and online services (our “Website” or “Platform”), as well as our other services, offerings, and other interactions (e.g., customer service inquiries, user collaborations, etc.) you may have with us (together with our Website and Application, collectively referred to as the “Services”). If you do not agree with these Terms, you should not use our Services. These Terms do not apply to any third-party applications or software that integrate with the Website or Application (“Third-Party Services”), or any other third-party products, services or businesses.

All the personal data collected is stored on secure servers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will take reasonable commercial effort to protect Your personal data, we cannot guarantee the complete security of Your data transmitted to the Website and/or Application and therefore any transmission is at Your own risk. Once we have received Your information, we will use strict procedures and security features to try to prevent unauthorized access.

1. SOURCES OF DATA

1.1. YOUPS generally collects, uses and discloses personal information about the following types of individuals:

- Customers;

- Consultants;

- Other individuals who may voluntarily choose to provide YOUPS with personal information; and/or

- Data collected from third parties that we did not obtain directly from you.

2. DATA PROCESS AND COLLECTION

2.1. We may process your account data (“Account Data”). The source of the account data is you, or an alienate data service. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and service and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract OR refine our Service through automated data processing.

2.2. We may process your information included in your personal profile on our website (“Profile Data”). The profile data may include your name, company name, address, telephone number, email address, profile pictures, website, social handles, gender, date of birth, interests and hobbies, confidential business information, marketing targets, educational details and employment details. The Profile Data may be processed for the purposes of enabling and monitoring your use of our website and the services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.3. We may process your personal data that is provided in the course of the use of our services (“Service Data”). You are the source of the service data that we use. The service data may be processed for the purposes of operating our website and/or application, providing our services, ensuring the security of our website and services, service accuracy, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration and utilization of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4. We may process Information contained in any inquiry you submit to us regarding services (“Inquiry Data”). The Inquiry Data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent.

2.5. We may process information relating to our client relationships, including client contact information] (“Client Relationship Data”). The Client Relationship Data may include your name, your employer or company name, your job title or role, industry, location, marketing targets, your contact details, and information contained in communications between us and you or your employer. The source of the client relationship data is you or your employer. The Client Relationship Data may be processed for the purposes of managing our relationships with clients, communicating with clients, keeping records of those communications and our services to clients. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our client relationships.

2.6. We may process information contained in or relating to any communication that you send to us and any information contained in any linked e-mail accounts (“Correspondence Data” or “Message Data”). The Correspondence Data may include the communication content and metadata associated with the communication. Our website and/or application will generate the metadata associated with communications made using the website and/or application contact forms and any other automated means. The Correspondence Data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with clients OR improving our services.

2.7. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or within any out-of-court procedure such as mediation or arbitration. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.8. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.9. In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal or business data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.10 Please do not supply any other person’s personal data to us, unless we prompt you to do so within our platform.

3. DATA USAGE

3.1. We may use the Personal Information collected by us in the following manner:

3.1.1. Monitor the use of the Website and/or Application for the technical administration of the AKP Solutions, Experts Connect or YOUPS websites and/or Application;

3.1.2. Use cookies to better understand how You interact with the Website and/or Application, to monitor aggregate usage by the users and web traffic routing on the Website and/or Application, and to improve the Website and/or Application; and

3.1.3. Use Personal Information, to conduct research and for further development of our services in order to provide You with a better, more intuitive and personalized experience.

3.1.4. to establish and manage client relationships, fulfill duties, and avoid conflicts of interest;

3.1.5. to establish and maintain commercial relationships with clients, suppliers, service providers and other third parties;

3.1.6. to establish, manage and terminate contractual and partnership relationships;

3.1.7. to conduct surveys, research and evaluations;

3.1.8. to develop, enhance, market, sell or otherwise provide YOUPS’s products and services;

3.1.9. to market, sell or otherwise provide products and services of third parties with whom we have a commercial relationship;

3.1.10. to distribute our newsletters and other informational e-mail communications and other material to individuals on our mail and e-mail lists;

3.1.11. to develop and manage our business and operations;

3.1.12. to detect and protect YOUPS and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activity;

3.1.13. to audit compliance with our policies and contractual obligations;

3.1.14. as permitted by, and to comply with, any legal or regulatory requirements or provisions; and

3.1.15. for any other purpose to which you consent.

3.2. We do not disclose your personal and business data to any third-party other than what is stated in this Section.

3.3. We may disclose your personal, marketing, and business data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.4. We may disclose personal, marketing, and business data to our IT suppliers or subcontractors insofar as reasonably necessary for the services provided by AKP Solutions Inc.

3.5. In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.6. In case that we will be under a duty to disclose or share Your personal data with or without Your consent, and with or without notice in order to comply with any legal obligation, including without limitation a subpoena, court order, or search warrant.

3.7. Personal data that we process may be stored for a period of time after you no longer use our website or services. The personal data stored for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

3.8. The time periods for which we retain your information depends on the type of information and the purposes for which we use it. We will keep your information for no longer than is required or permitted.

3.9. For further clarity, we may also retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4. NOTIFICATIONS AND CONSENT

4.1. Subject to this Policy and applicable legislation, YOUPS will identify the purposes for collection, use and disclosure in advance of collection, and will notify the individual of the purposes for collection, use or disclosure at or before the time of collection.

4.2. YOUPS will generally obtain consent from the individual at or before the time of collection of personal information. However, there are a number of exceptions in that in some circumstances, such as with employee personal information, YOUPS does not require consent to collect, use or disclose personal information with respect to employees, but may be required to provide notification in advance.

4.3. In other circumstances, specifically those set out in applicable legislation, the law does not require that YOUPS obtain consent or provide notification. YOUPS reserves all its rights to rely on all available statutory exemptions and exceptions.

4.4. You may voluntarily submit Personal Information to us for purposes such as asking a question, obtaining information, reviewing or downloading a publication, subscribing to a newsletter or a mail or e-mail list, participating in a seminar or other event, and participating in contests and surveys. If you are a registered user of an online service, we may combine and store Personal Information about your use of our website and/or application and information you have provided to us with certain other online and offline information we may have collected.

4.5. We may send you marketing or promotional e-mail communications. In this process, we may collect certain information such as the date and time you first opened our e-mail communications, the number of times you open our e-mail communications, the number of instances you click through our articles and your total click-through activity on the contents of our e-mail communications. We may also combine and store any such information to manage and improve our e-mail communications. If you no longer wish to receive any future marketing or promotional material from us, our promotional e-mail communications will include instructions on how to unsubscribe and inform us of your preferences.

4.5. We may include links to other websites on our website and/or application. These third party websites may collect your Personal Information and they may have different privacy policies and practices than YOUPS. We do not assume any responsibility for the privacy practices, policies or actions of the third parties operating these websites. We strongly encourage you to read the privacy policies of these websites to enable you to make an informed decision whether or not to provide your Personal Information to the websites’ operators.

5. AMENDMENTS

5.1. We may update this policy from time to time for any reason by publishing a new version on our website. Each version will apply to information collected while it was in place.

5.2. You should check this page occasionally to ensure you are satisfied with any changes to this policy.

6. SECURITY

6.1. We recognize our legal obligations to protect the personal information we have gathered about individuals. We have therefore made arrangements to secure against unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information. These arrangements may include physical security measures, network security measures, and organizational measures such as non-disclosure agreements and need-to-know access.

7. GOVERNING LAW

Apace LTD. will apply to any Dispute (except where prohibited by law).

To the fullest extent allowable by law, the laws of Kazakhstan., without regard to its conflict of laws rules, shall apply to any Dispute arising out of or relating to this Terms, the Service, or your relationship with YOUPS.

8. Contact Us

If you have any questions about these Terms, please contact us at:

Mail: Kazakhstan, Astana, Almaty area, Prosepkt Abylay hana, building 23, apt. 14, 010000

Email: support@youps.io