Privacy Policy

SPRYNTO LLC Privacy Policy

This Privacy Policy (hereinafter referred to as the Policy) includes information that SPRYNTO LLC (hereinafter referred to as SPRYNTO) can obtain about Internet users (hereinafter referred to as Customers) when they use SPRYNTO services, websites, programs, products, and services (hereinafter referred to as SPRYNTO Services). The Policy applies only to SPRYNTO Services.

SPRYNTO does not control and is not responsible for third-party websites/services that Customers can access through links available in SPRYNTO Services, including information about Customers obtained by third parties.All terms and conditions not mentioned in this Policy and not used in SPRYNTO Services are provided in the Rules of Use of SPRYNTO Services and other agreements governing the provision and use of SPRYNTO Services. By using SPRYNTO Services, the Customer agrees to the terms and conditions of this Policy and the processing of their personal information as stated here. If the Customer does not agree with these terms, they should refrain from using SPRYNTO Services.

Customer information received and processed by SPRYNTO.

Within this Policy, the Customer's personal data is explained as follows:

• SPRYNTO may collect and process Customer information, including Customer information provided by third parties, while using SPRYNTO Services. This includes personal information (except for bank card information) provided by the Customer during registration or use of SPRYNTO Services, including the execution of any SPRYNTO agreements. Note that the Customer can provide only necessary information when using certain SPRYNTO services.
• When using SPRYNTO Services, information automatically transmitted to SPRYNTO by the Customer's device, including IP address, cookies (text files stored in the Customer's browser), information about the Customer's browser (or other programs providing access to SPRYNTO Services), time of access, and the address of the requested page, may be collected
• When reviewing SPRYNTO websites, anonymized statistical information is automatically collected from cookies, including:

1. Type of action performed on the site (click, swipe, etc.);
2. Date and time of action;
3. URL of the page;
4. Referrer;
5. IP (without working with IP addresses in statistics);

User-Agent;

1. Client ID (browser identifier with cookies);
2. Screen resolution;
3. Class of the clicked HTML element;
4. Information about the viewed data by the Customer in all sections of the service;
5. Facts of filling in forms/queries on the SPRYNTO website, including information about errors during their filling.

• By using the website, the Customer agrees that SPRYNTO can use statistical information and cookies, excluding information about the viewed data in the following sections: "Products," "Services," and "Parameters," for marketing campaigns, including the distribution of offers and receipt of rewards within the campaign. The Customer can manage cookies by changing their browser settings. However, blocking cookies may result in certain components of the from-pay.az website not working correctly.
• When using third-party resources (e.g., chats/forms/social media), SPRYNTO can obtain public information. This data may include information provided by the Customer, including comments and reviews about SPRYNTO Services.

SPRYNTO uses such information to improve the quality of customer service.

• SPRYNTO may also process certain information to facilitate or prevent actions that violate the law or the requirements of the agreement when using SPRYNTO Services, e.g., by identifying IP addresses or device identifiers.
• SPRYNTO may receive information about the Customer from its partners, e.g., to create a connection between SPRYNTO and the Customer when entering into an agreement with a third party and to transfer information about this Customer.
• SPRYNTO does not check and does not verify the accuracy of personal information provided by Customers within the contracts with SPRYNTO, except for the cases and rules stipulated in the contracts. However, SPRYNTO assumes that the Customer provides correct and sufficient personal information and keeps it updated.

Purposes of collecting and processing personal information of Customers:

• Except for cases where the law requires the collection and storage of certain personal information, SPRYNTO collects and stores only the personal information necessary to provide SPRYNTO Services or to conclude contracts with Customers. The storage of personal information is carried out in accordance with the legislation of the Republic of Azerbaijan and, if not specified in the contract for the provision of SPRYNTO Services, within the period necessary to achieve the processing purposes.
• SPRYNTO may use Customer's personal information for the following purposes:

- Execution of contracts with SPRYNTO, including identification/simplified identification of Customers, provision of services to Customers, execution of Customer orders related to money transfers and/or refunds of funds;

- Communication. This includes sending notifications, queries, and processing requests and complaints from Customers, including customer support;

- Improving the quality of SPRYNTO Services, facilitating the use of SPRYNTO Services, preparing new SPRYNTO Services, and offering personalized SPRYNTO Services to Customers;

- Conducting statistical and other research based on anonymized information;

- Conducting marketing campaigns for Customers, including sending proposals for participation in promotions and receiving prizes within the promotions; distributing advertising and information materials by telecommunication networks, including by phone, fax, mobile radio.

- Prevention of conditions that facilitate actions using the services that are contrary to the requirements of the law or the contract under which the service is provided to the Client.

Terms of processing and transfer of customer's personal data to third parties:

• As for the client's personal data, its confidentiality is guaranteed.
• SPRYNTO has the right to transfer the Client's personal data to third parties in the following cases: – The Client has given his consent to such actions.

– To use a certain SPRYNTO Service or a service of a SPRYNTO partner, including for the execution of the Customer's order, a transfer is necessary. In particular, Personal Data may be provided to third parties in the following categories:

 - Credit organizations and other organizations involved in the implementation of transfers.

- SPRYNTO's marketing partners and other counterparties.

– SPRYNTO may provide its Clients with access to certain information (such as statistical data) for marketing and other research purposes, as well as other information that allows the Client to transmit relevant and potentially interesting advertisements, including third-party organizations.

– SPRYNTO may provide access to some information about the Customer's payment transactions, which is the basis for determining the partner's ability to provide discounts (rewards) to such Customer by SPRYNTO, incentives in connection with the fulfillment of certain obligations by the Customer. Conditions established by the SPRYNTO partner, as well as in the Bonus account of the Customer who is a member of the SPRYNTO Loyalty Program, when such access is related to the possibility of providing the Customer with additional conditions for using Privileges.

– When the Client uses the services provided by SPRYNTO partners, information about the Client may be provided to such persons in accordance with the scope and purposes necessary for the proper provision of services to the Client or to increase the level of convenience of their use. For example, for filling out registration forms in advance, which speeds up the process of going through the registration procedure in the services provided by SPRYNTO partners.

1. Data storage partners.
2. Partners participating in the prevention of situations that lead to actions contrary to the requirements of the law or the contract under which the service is provided to the Client using the SPRYNTO service.
3. Public information. The SPRYNTO Services may contain forums and/or chat areas where Customers can exchange ideas and communicate with each other. When posting a message in a forum or chat area, the Customer must remember that such information will be publicly available online and that such posting is at the Customer's own risk.
4. Transfer of control. The transfer occurs as part of a sale or other transfer (in whole or in part) of a business, and the transferee transfers all obligations to comply with the terms of this Policy with respect to the personal data it receives;
5. The transfer is provided for by other legislation in force in the Republic of Azerbaijan or in the manner established by law;

Requirements of applicable law in order to protect the rights and legal interests of SPRYNTO or third parties in cases where SPRYNTO has reasonable grounds to believe that the Customer has violated the terms of the current agreement with SPRYNTO.

When processing personal data of customers, SPRYNTO is guided by the Law "On Personal Data" and other normative legal acts regulating relations in the field of ensuring the security of personal data.

Disclosure of anonymous information. SPRYNTO may also disclose anonymous information (ie, information that does not directly or indirectly identify the Customer) as well as aggregated information (information about groups and categories of Customers) to partners. SPRYNTO may also allow partners to collect anonymous and aggregated information to enable Customers to use certain features of the Services, which may then transmit that information to SPRYNTO.

Modification and deletion of personal data by the customer, as well as access to it:

Changing and deleting the customer's personal data is carried out in accordance with the agreements on the use of the relevant SPRYNTO Services. As part of the SPRYNTO Services, the Client may be given the ability to change (update, add to) or delete the information provided by the Client or part of it. The use of the relevant functionality is governed by the agreements applicable to this SPRYNTO Service. To the extent permitted by applicable law, SPRYNTO will notify each recipient to whom personal information is disclosed of the modification or destruction of personal information, unless this is impracticable or requires a disproportionate effort. In accordance with the requirements of the law, SPRYNTO may be required to process / store the Customer's personal data obtained during the use of the SPRYNTO Services. Such processing/storage is carried out by SPRYNTO in the cases, grounds and periods established by law.

Right of access:

In accordance with current legislation, the Customer has the right to access the information received by SPRYNTO, which means that you have the right to request information about:

(a) purposes of processing;

(b) categories of processed data;

(c) the category of recipients to whom the Customer's personal data is or will be transferred;

(d) Information (copy) may be submitted to SPRYNTO in writing or by other means of communication, unless otherwise specified in the service interface. If SPRYNTO has reason to doubt the identity of a Customer making a request under the Policy, SPRYNTO may request additional information necessary to verify the identity of such Customer. The request for information (copy) will be considered within one month (30 days) from the date of its receipt by SPRYNTO. SPRYNTO may extend this period by two months (60 days) depending on the complexity and number of requests. SPRYNTO will notify the Customer of such extension, indicating the reasons for such extension. If there is no clear basis for the request or if there are many requests, SPRYNTO may charge an appropriate fee for processing the request (including administrative costs) or refuse to fulfill it. SPRYNTO will also not be able to provide the Customer with published information about him in the manner specified in the Policy. The customer has the right to independently transfer the data received from SPRYNTO to another controller, if SPRYNTO has the technical capabilities, through SPRYNTO.

Right to object:

To the extent permitted by applicable law, the Customer may withdraw any consent previously given or object to the processing of their personal data on legal grounds. In some cases, withdrawal of consent will mean that the Customer will not be able to use the SPRYNTO Services. In accordance with the current legislation, the Customer has the right to file a complaint with the supervisory authority.

Children's Use of SPRYNTO Services:

The SPRYNTO Services are not intended for children without the consent of a legal representative. SPRYNTO may use the information of these individuals for the purposes of age verification and the application of certain age restrictions.

Measures taken to protect customers' personal data:

– SPRYNTO takes necessary and sufficient organizational and technical measures to protect the Customer's personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

– SPRYNTO ensures the security of personal data during processing and takes necessary organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as other factors. SPRYNTO implements the privacy regime and monitoring of their compliance with the implementation of additional protection measures based on the requirements of the legislation of the Republic of Azerbaijan, standards and internal organizational-administrative documents to prevent illegal actions related to such information.

– SPRYNTO has the right to offer the Customer to change and/or add to this Policy by publishing a new edition of the Policy on the website (link). The User's acceptance of such an offer is a definitive action to use any of the SPRYNTO Services under the new terms.

- This Policy and the relationship between the Customer and SPRYNTO arising from the application of the Privacy Policy are subject to the laws of the Republic of Azerbaijan and normative legal acts regulating relations in the field of ensuring the security of personal data.

Interaction with Customers on the processing of personal data:

- You can send questions or comments about the policy to the e-mail address info@sprynto.az.

– SPRYNTO has the right not to answer questions that do not relate to the provisions of the Policy, and this does not deprive the Customer of the opportunity to send such questions to SPRYNTO at the addresses indicated on the SPRYNTO website.