Privacy Policy

Updated February, 06,2024

Please read carefully this Privacy Policy (hereinafter - Policy) which extends its effect to the site https://kirsan.co.uk (hereinafter - Kirsan Site) to understand our principles and rules of processing the Information provided by you.

We value your trust, respect your privacy and ensure the security of your data.

Consent to this Policy is a condition of use of the Site and its Services.

The Policy extends its effect to all information that Kirsan may obtain about you during the use of the Site and (or) the Services.

1. Terms and definitions

  • 1.1. Kirsan - Kirsan House LTD 71-75, Shelton Street, Covent Garden, London, WC2H 9JQ, UNITED KINGDOM, Registered in UNITED KINGDOM, Company number 14672896, an organization that owns the site https://kirsan.co.uk and provides financial, technical support of the site’s existence and operation.
  • 1.2. The User is a natural person of legal age, who is able by their actions to acquire civil rights for themself and exercise them independently, as well as to enter into civil obligations, independently perform them and bear responsibility in case of their failure, which accepted the terms of this document and uses the services of the Site.
  • 1.3. The site is an Internet site that has a domain name: https://kirsan.co.uk, used by Kirsan to provide services whose terms of use refer to this Policy.
  • 1.4. Services - functionality of the Site (programs, services, products, functions, interfaces, web forms), placed on the Site.
  • 11.5. Information - all information, including personal data, i.e., any information relating to a directly or indirectly defined or defined individual (subject of personal data), which Kirsan House Ltd may receive information about the User during the use of the Site and (or) the Services from the User’s devices.
  • 1.6. Confidentiality of information - the requirement not to transfer certain information to third parties without the consent of its owner, except in cases established by the Policy, which is mandatory for the person who has obtained access to such information.
  • 1.7. «Cookies» - files containing official information about the visit to the site, sent by the server to the User’s device.
  • 1.8. Services - providing access to special services and other services rendered by Kirsan using the Site and/or Services.
  • 1.9. Personal Account - a site service consisting of a set of linked pages of the site, accessible only to registered users, providing access to user’s personal data, providing the opportunity to purchase and/or alienate Tokens, the opportunities of the affiliate program, containing the history and results of the user’s relationship with Kirsan and other information.

2. General provisions

  • 2.1. The purpose of this Policy is to ensure that the Information is properly protected against illegal access and disclosure.
  • 2.2. Users who intend to use the Site for the first time shall undertake to have prior knowledge of the provisions of this Policy.
  • 2.3. Site users have access to the current version of the Policy.
  • 2.2. The Kirsan Account information received is only validated if it is a Kirsan client.
  • 2.3. Kirsan excludes in its activities the intention to organize public sources of personal data of Users.
  • 2.4. Kirsan allows for the trans-border transmission of Information on the territory of States that are parties to the Council of Europe Convention for the Protection of Natural Persons in the Automated Processing of Personal Data, as well as other foreign States, providing adequate protection of the rights of subjects of personal data, if such transfer is carried out for the purposes of performance of the contract concluded with the User.
  • 2.5. The User ceases to use the Site and (or) the Services in case of disagreement with the terms of the Policy.
  • 2.6. Personal data of the User to be processed by Kirsan:
    • ● User’s nickname;
    • ● User’s legal name;
    • ● User’s address;
    • ● User’s phone number;
    • ● Cookies and other files necessary for the correct operation of the Site and/or Services;
    • ● Email Address;
    • ● Address of the User’s location (geolocation);
    • ● Other personal data reflected in the individual consent to the processing of personal data.
  • In addition, the site collects and processes anonymized data about visitors, obtained through Internet statistics services.

3. Purpose of processing Information and composition of information processed

3.1. Kirsan processes the Information for the following purposes:

  • ● User identification and update of Account information on the Site. For this purpose, the information specified in the form of the User’s questionnaire is processed;
  • ● providing access to the Services and Services of the Site. For these purposes, geolocation, nickname, cookies, electronic address, and other personal data included in the separately obtained consent to the processing of personal data are to be processed);
  • ● communication with the User, including sending him notifications, messages, inquiries and information related to the services provided and (or) the Services used; For these purposes must be processed: nickname, e-mail address;
  • ● Provide the user with access to advertising, marketing, training events, including webinars and online courses; provide analytical materials. For these purposes, the data is processed: nickname, email address, status of relationships with Kirsan;
  • ● Improving the quality of Services. For this purpose: geolocation, nickname, email address, cookies, and other personal data are processed;
  • ● information about Kirsan products and services, including promotional materials, and the implementation of partner program terms and conditions.
  • Subject to processing: nickname, email address, cookies;
  • Kirsan excludes the collection and analysis of personal information such as gender and race; intimate information, including sexual orientation and everything related to sexual life; health status; philosophical views; religious beliefs; political views, etc.

4. Information security requirements

  • 4.1. Kirsan ensures that information is stored in secure systems that are accessible only to a limited number of persons with special access rights to such systems and with which relevant confidentiality agreements have been signed.
  • 4.2. Kirsan provides sufficient technical and organizational measures to protect the Information from unauthorized, accidental or unlawful destruction, loss, modification, misuse, disclosure or access, as well as other illegal forms of processing. These security measures were implemented taking into account the modern level of equipment, the cost of their implementation, risks associated with the processing and nature of the Information.
  • 4.3. Whenever Kirsan uses third party services (including, but not limited to, third-party KYC services, third-party cookies services), Kirsan acts under assumption such services are compliant with applicable laws and regulations. However, Kirsan, unless otherwise expressly stated and/or directly results from the data on the appropriate open registers, does not execute control over such entities, hence shall be indemnified and held harmless against any claims resulting from any data breaches, leaks or alike events, experienced by such third parties.

5. Storage of information

  • 5.1. Kirsan stores the Information no longer, than the purpose of the Information processing requires, or until the User withdraws consent to the processing of personal data.
  • 5.2. After implementing the stated objectives or withdrawing consent to the processing of personal data in the form of deletion of the account (account) of the User, Kirsan destroys the personal data of users in accordance with the internal regulations of Kirsan, with the issuance of the appropriate certificate, indicating the destroyed personal data.

 

6. Rights and obligations of users and owner of the site.

  • 6.1. When registering on the site and (or) the services of the site, the User marks in the corresponding checkbox the consent to the privacy policy, thereby he agrees to the processing of his personal data, and also informs that the terms of the Policy are clear to him.
  • 6.2. The user has the opportunity to obtain information from Kirsan  concerning the processing of the Information, including copies of personal data processed by Kirsan, by sending a request through the Site https://kirsan.co.uk.
  • 6.3. The user periodically updates and, upon modification, adjusts his personal data by means of site services or by sending a request to the Site https://kirsan.co.uk.
  • 6.4. In case of detection of inappropriate processing of the Information, as well as reduction of marketing activities Kirsan the User has the right to initiate restriction of its processing.
  • 6.5. Consent to the processing of personal data may also be withdrawn by the User based on his written application sent through the https://kirsan.co.uk Site. In doing so, the User should bear in mind that the provision of Services to him and the provision of Services on the Site might be terminated.
  • 6.6. Requests sent by the user must meet certain content requirements, namely, information about the identity document number, the date of its issuance and the issuing authority, information confirming the User’s relationship with Kirsan, or information about the processing of Kirsan personal data under other circumstances, as well as the User’s signature.
  • 6.7. The User shall take sufficient measures to ensure the confidentiality of the credentials (login and password) used to access the Services to avoid their disclosure or unauthorized access.
  • 6.8. Measures to remove User Information from the Site and (or) Kirsan shall take its Services when certain conditions are met:
    • - achieving the objectives of processing the Information;
    • - revocation of consent by the user on the basis of which the Information was processed, except in cases where Kirsan is entitled or obliged to continue processing the Information;
    • - Detection of illegal information processing.
  • 6.9. Kirsan undertakes to delete User Information from its information systems within 30 (30) days of the conditions specified in 7.8 of the Policy, wherein the user accounts are blocked, the personal data are blocked, the personal data is registered (name, first name) are removed from their description.
  • 6.10. Use of Kirsan Information obtained from a user is only possible for the purposes set out in section 3 of the Policy.
  • 6.12. The Kirsan Information is stored in secret and may only be disclosed with the consent of the user. The sale, exchange, publication, or disclosure by other possible means of the transmitted Information shall not be permitted, except for the transmission of the Information to authorized state bodies on the grounds and in the manner prescribed by law.
  • 6.13. The activities of Kirsan are in accordance with applicable personal data protection legislation as well as the terms of the contracts between Kirsan and its Users.
  • 6.14. In the event of an information security incident that may result in (or result in) a breach of the privacy and integrity of users' personal data, Kirsan notifies them of the incident within 24 (twenty-four) hours after detection and localization (establishment of details) of the incident.

7. Transmission of Information to third parties

7.1. Access to User Personal Data by designated Kirsan persons or competent authorities is possible only in cases provided by law, as well as by persons specified in consent to the processing of personal data and this Policy.

8. Responsibility

8.1. Liability for damage caused in connection with the improper use of the Information certainly follows for the violation committed against the perpetrators, be it Kirsan or users of the Site.

9. Additional conditions

9.1. Kirsan is open to questions and suggestions from Users, including the execution or modification of Policy Terms. Questions and suggestions in this part should be sent through the Site https://kirsan.co.uk.

10. Changing the Policy Environment

  • 10.1. Kirsan may change the terms of the Privacy Policy unilaterally.
  • 10.2. Posting a new version of the Policy on the Site, after the changes made to it, shall be considered as a proper notice to the user. His consent to the new version of the Policy shall be expressed by continuing the use of the Site and (or) its Services after the publication of the new edition of the Policy on the Site.
  • 10.3. It is the User’s responsibility to review the Policy on each visit to the Site.
  • 10.4. After posting on the site, the new version of the Policy enters into force. Previous versions of the Policy are saved on the site; users have the opportunity to familiarize themselves with them.

11. Procedures for filing and handling complaints

  • 11.1. The User is obliged to check the actions performed through the Account and in case of any inconsistency, to notify Kirsan within two months from the moment of such action.
  • 11.2. In the event of any complaints or suggestions, the User may contact Kirsan, including by e-mail or through the Kirsan hotline. In accordance with the established rules, Kirsan conducts internal procedures for dealing with complaints and proposals that are sent to Kirsan. Kirsan is obliged to respond to the received complaints and proposals, in accordance with the procedures established by it, respecting the terms, deadlines and requirements of the legislation. The written requests of the User shall be answered in writing.

 

GENERAL DISCLAIMER

THE INFORMATION, CONTENT AND DOCUMENTS ACCESSED FROM OR THROUGH THE SITE ARE PROVIDED “AS-IS,” “AS AVAILABLE,” WITH “ALL FAULTS”, AND ALL WARRANTIES, EXPRESS OR IMPLIED, ARE DISCLAIMED (INCLUDING BUT NOT LIMITED TO THE DISCLAIMER OF ANY IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE). THE INFORMATION AND SERVICES MAY CONTAIN BUGS, ERRORS, PROBLEMS OR OTHER LIMITATIONS. WE AND OUR AFFILIATED PARTIES HAVE NO LIABILITY WHATSOEVER FOR YOUR USE OF ANY INFORMATION OR SERVICE, EXCEPT AS PROVIDED IN THE USER AGREEMENT. IN PARTICULAR, BUT NOT AS A LIMITATION THEREOF, WE AND OUR AFFILIATED PARTIES ARE NOT LIABLE FOR ANY INDIRECT, SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES (INCLUDING DAMAGES FOR LOSS OF BUSINESS, LOSS OF PROFITS, LITIGATION, OR THE LIKE), WHETHER BASED ON BREACH OF CONTRACT, BREACH OF WARRANTY, TORT (INCLUDING NEGLIGENCE), PRODUCT LIABILITY OR OTHERWISE, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. THE NEGATION AND LIMITATION OF DAMAGES SET FORTH ABOVE ARE FUNDAMENTAL ELEMENTS OF THE BASIS OF THE RELATIONSHIP BETWEEN US AND YOU. THIS SITE AND THE PRODUCTS, SERVICES, DOCUMENTS AND INFORMATION PRESENTED WOULD NOT BE PROVIDED WITHOUT SUCH LIMITATIONS. NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM US THROUGH THE SITE OR OTHERWISE SHALL CREATE ANY WARRANTY, REPRESENTATION OR GUARANTEE NOT EXPRESSLY STATED IN THIS AGREEMENT. IN NO EVENT SHALL Kirsan BE LIABLE FOR ANY DIRECT, INDIRECT, CONSEQUENTIAL, INCIDENTAL, SPECIAL AND EXEMPLARY DAMAGES, OR ANY DAMAGES WHATSOEVER, ARISING FROM THE USE OR PERFORMANCE OF THIS SITE, INCLUDING THE CONTENT AND MATERIALS PROVIDED AND THIRD PARTY PRODUCTS OR SERVICES YOU ACCESS. Kirsan DISCLAIMS ALL WARRANTIES THAT THE LINKS PROVIDED BY THIRD PARTIES AND THEIR DESTINATION WEB PAGES, PRODUCTS OR SERVICES, ARE SAFE FOR USE, ERROR AND VIRUS FREE, FUNCTIONAL, AND SECURE. Kirsan MAY SUSPEND OR CHANGE THE CONTENT AND DESIGN OR STRUCTURE OF THE SITE AT ANY TIME WITHOUT ANY PRIOR NOTICE TO THE USERS, AND IS NOT RESPONSIBLE FOR ANY INCONVENIENCES, CONSEQUENCES SUCH CHANGES MAY CAUSE. ALL RESPONSIBILITY OR LIABILITY FOR ANY DAMAGES CAUSED BY VIRUSES CONTAINED WITHIN THE ELECTRONIC FILE CONTAINING A PRODUCT, INFORMATION OR SERVICES IS DISCLAIMED.

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