PRIVACY POLICY
This is a machine-assisted translation provided for convenience only. In case of any discrepancy, the Ukrainian-language version of this document is legally binding.
This Privacy Policy defines the procedure for processing and protecting Personal Data while using the Loka Platform, through which the Company provides Services.
In this Policy, the terms "Owner" and "Client" are used exclusively to denote the roles of Platform users. The Company processes the Personal Data of users regardless of the role in which they use the Platform.
References to the words "you", "your" (or similar words) mean the User of the Platform.
References to the words "we", "our", "us" (or similar words) mean the Company.
The words "he" / "she" and their derivatives in the text of this document apply to persons of any sex, depending on the context.
1. DEFINITIONS
1.1. Account — a personal record of the User on the Platform, created during registration and used to identify the User, access the Platform's functionality, and store settings, activity history and documents generated while using the Platform.
1.2. Company — the legal entity on whose behalf Services are provided to Users.
1.3. Loka Platform (hereinafter referred to as the "Platform" or "Loka") — a software and hardware complex and a set of technical and information solutions owned by the Company, which includes (depending on available functionality) a Telegram application, a web interface, software modules, databases and other components through which the Company provides Services to Users.
1.4. Owner — an individual or legal entity that places a property listing on the Platform and provides such property for rent to a Client in accordance with the terms of the Rental Agreement concluded between the Owner and the Client.
1.5. Client — an individual or legal entity that uses the Platform for the purpose of booking property and receives such property for rent from an Owner in accordance with the terms of the Rental Agreement concluded between the Owner and the Client.
1.6. User — a general term for the Client and the Owner.
1.7. Personal Data — any information that is not publicly available and allows, directly or indirectly, the identification of a User, for example: first name, last name, phone number, IP address.
1.8. Services — information and technical services provided by the Company through the Platform, consisting of giving the User access to the Platform's functionality, including the ability to create and use an Account, place and view listings, search for and book property, exchange messages between the Owner and the Client, generate, store and provide access to documents/confirmations created while using the Platform, and provide informational support regarding use of the Platform.
1.9. Third Party — an individual or legal entity, government institution, organization or body, other than the Company or the User.
1.10. Cookies — a piece of information in the form of text or binary data used by the Company while you use the Website to obtain additional information about you.
1.11. User Consent (hereinafter — "Consent") — a voluntary, specific, informed and unambiguous expression of will, by which the User, by means of a statement or a clear affirmative action, agrees to the terms of processing of their Personal Data.
2. GENERAL PROVISIONS
2.1. The Company processes and stores Personal Data based on the principles of lawfulness, fairness and transparency in accordance with the Law of Ukraine "On Personal Data Protection" and this Privacy Policy, to the extent necessary to provide Services through the Platform and ensure its functioning.
2.2. The Company may engage Third Parties to ensure the operation of the Platform and the provision of Services (in particular technical services, electronic signature services, payment/financial services and other integrations). Where Personal Data is transferred to such Third Parties, it is processed in accordance with the terms of this Privacy Policy and/or the policies of the relevant Third Parties. The Company is not liable for the manner in which Personal Data is processed by Third Parties beyond the Company's control.
3. PERSONAL DATA
3.1. The Company may collect the following Personal Data about the Owner: 3.1.1. last name, first name and patronymic; 3.1.2. phone number; 3.1.3. email address; 3.1.4. Account data on the Platform (identifier, username, profile photo — if available); 3.1.5. property data that the Owner enters in the listing, which may contain Personal Data (in particular address, photos/videos, description, contacts); 3.1.6. verification data (if any): details from an identity document and an image/copy thereof, as well as a facial image (selfie) and other materials provided to confirm identity; 3.1.7. data provided by the Owner to the Company when contacting support (content of the request, attached materials).
3.2. The Company may collect the following data about the Owner (legal entity): 3.2.1. full name; 3.2.2. USREOU code; 3.2.3. location; 3.2.4. Personal Data of the representative (last name, first name and patronymic (if any), position, contact phone number, email address); 3.2.5. a document confirming the representative's authority (if any) and/or details from such document; 3.2.6. Account data on the Platform (identifier, username, profile photo — if available); 3.2.7. property data that the Owner enters in the listing, which may contain Personal Data (in particular address, photos/videos, description, contacts); 3.2.8. verification data (if any): details from the representative's identity document and an image/copy thereof, as well as a facial image (selfie) and other materials provided to confirm identity; 3.2.9. data provided by the Owner to the Company when contacting support (content of the request, attached materials).
3.3. The Company may collect the following Personal Data about the Client: 3.3.1. last name, first name and patronymic (if any); 3.3.2. phone number; 3.3.3. email address; 3.3.4. Account data on the Platform (identifier, username, profile photo — if available); 3.3.5. booking data (selected dates, number of persons, comments, other information entered by the Client when making a booking); 3.3.6. data provided by the Client during message exchanges with the Owner through the Platform; 3.3.7. data provided by the Client to the Company when contacting support (content of the request, attached materials).
3.4. The Company may collect the following data about the Client (legal entity): 3.4.1. full name; 3.4.2. USREOU code; 3.4.3. location; 3.4.4. representative's data (last name, first name and patronymic (if any), position, contact phone number, email address); 3.4.5. a document confirming the representative's authority (if any) and/or details from such document; 3.4.6. Account data on the Platform (identifier, username, profile photo — if available); 3.4.7. booking data (selected dates, number of persons, comments, other information entered by the Client when making a booking); 3.4.8. data provided by the Client during message exchanges with the Owner through the Platform; 3.4.9. data provided by the Client to the Company when contacting support (content of the request, attached materials).
3.5. The Company may collect the User's payment data necessary to receive and/or make payments, in particular a crypto wallet address (USDT) and other payment identifiers. Such payment data may be collected and processed by a special payment service (payment infrastructure provider), and the Company only accesses and/or processes it to the extent necessary to ensure the payment is carried out, transaction accounting, and provision of the Services.
3.6. The Company may process photos and videos that the User uploads or provides through the Platform while using the Services (in particular for listings, confirmations of transfer/return of property, requests to the support service, and other actions within the Platform's functionality).
3.7. The Company does not collect or process sensitive Personal Data of the User, such as racial or ethnic origin, political views, religious or philosophical beliefs, trade union membership, genetic or biometric data, information about health, sex life or sexual orientation.
3.8. While using the Website or receiving Services, the Company may automatically collect the following User Data: 3.8.1. IP address; 3.8.2. time zone and language settings; 3.8.3. operating system, device type and screen resolution; 3.8.4. country of location; 3.8.5. data on use of the Platform, in particular the date and time of login/logout, navigation routes within the Platform, screen/page response time, loading errors, duration of stay in individual sections, activity on the Platform (in particular clicks/taps, scrolling), as well as data on requests to the support service through available communication channels.
3.9. The Company may use messengers and other communication platforms (in particular Telegram) to interact with Users and provide support. Personal Data received by the Company during such communication is processed in accordance with this Privacy Policy.
3.10. At the same time, the User independently determines what data they post or transmit through the relevant platforms, and the processing of such data by the owner/operator of the relevant platform is governed by its own privacy policy and terms of use.
3.11. The Company has the right to collect and receive Personal Data as follows: 3.11.1. during User registration on the Platform and creation/use of an Account; 3.11.2. while the User fills in their profile and provides data while using the Platform's functionality (in particular placing listings, making bookings, exchanging messages); 3.11.3. while the User uploads materials through the Platform (in particular photos, videos, documents and other files, if applicable); 3.11.4. during the User's verification (if any), in particular by providing a document and a facial image (selfie); 3.11.5. while making payments through the payment service (payment infrastructure provider), if applicable; 3.11.6. when the User contacts the Company's support service and communicates with the Company through available communication channels.
3.12. The Company has the right to use Personal Data for the following purposes: 3.12.1. to create and administer the User's Account and provide access to the Platform; 3.12.2. to provide the Services and ensure the functioning of the Platform, including processing the User's actions within the Platform's functionality; 3.12.3. to ensure communication between the Owner and the Client within the Platform; 3.12.4. to generate, store and provide access to documents/confirmations created while using the Platform; 3.12.5. to carry out the User's verification (if any); 3.12.6. to ensure the security of the Platform, prevent fraud and abuse, and resolve technical errors and incidents; 3.12.7. to process the User's requests to the support service, communicate with the User, and provide informational support; 3.12.8. to comply with the requirements of Ukrainian law, as well as lawful requests from government authorities and courts.
4. TRANSFER OF PERSONAL/STATISTICAL DATA
4.1. The Company may transfer Personal Data to entities with which it cooperates in implementing and providing the Services: 4.1.1. Payment service / payment infrastructure provider / bank. To accept and/or make payments (including in the form of crypto payments, if applicable), Personal Data may be transferred to the relevant payment service (payment infrastructure provider) and/or bank. 4.1.2. Electronic signature services. To generate, sign and store documents while using the Platform, Personal Data may be transferred to electronic signature services (in particular Vchasno, Diia.Signature or other similar services, if applicable). 4.1.3. Contractors and employees. The Company may transfer Personal Data to employees and/or contractors engaged to ensure the operation of the Platform and provision of the Services, in particular persons providing legal, tax, accounting, marketing, technical and IT services, to the extent necessary to perform their functions. 4.1.4. Counterparties in the event of corporate changes. The Company has the right to disclose or transfer Personal Data within the framework of agreements or procedures related to acquisition, merger, financing, corporate reorganization, joint venture, sale of assets, or insolvency/bankruptcy proceedings. 4.1.5. Courts, law enforcement and government authorities. The Company has the right to transfer Personal Data in order to comply with the requirements of Ukrainian law and/or at the lawful request of authorized bodies, in particular on the basis of a court decision. 4.1.6. Legal and tax advisors. The Company may transfer Personal Data to legal and/or tax advisors, auditors and other professional advisors to the extent necessary to obtain advice, ensure legal support for the Company's activities, and comply with the requirements of Ukrainian law. 4.1.7. Owner and Client. Within the Platform's functionality, Personal Data that a User provides while using the Platform (in particular contact data and other information necessary for communication, booking, and conclusion/performance of the Rental Agreement) may be made available to and/or transferred to the other User who is a party to the relevant interaction (the Owner or the Client). 4.1.8. Verification (KYC) services. To carry out identity verification and confirmation of Users' data, the Company may use the Diia.Sharing (Diia) service, which allows obtaining electronic copies of digital documents to the extent necessary to identify the User and conclude/perform transactions. 4.1.9. Analytical and technical services. To analyze Users' interaction with the Platform, improve its functionality, monitor performance and optimize the user experience, the Company may transfer anonymized and/or analytical/statistical data to analytics platforms (in particular PostHog).
5. USER CONSENT
5.1. By agreeing to the terms of this Privacy Policy, the Owner gives their Consent to: 5.1.1. the processing of their Personal Data by the Company for the purposes of registration on the Platform, creation and use of an Account, and provision of the Services; 5.1.2. the processing of Personal Data that the Owner provides while placing listings, communicating with Clients, and using other functional features of the Platform; 5.1.3. the processing and storage of documents and materials that the Owner uploads or generates through the Platform (in particular photos, videos and other files, if applicable); 5.1.4. carrying out the Owner's verification (if any), including the processing of identity document data and a facial image (selfie); 5.1.5. the processing of payment data and making/receiving payments through the payment service (payment infrastructure provider), as well as the transfer of the necessary Personal Data to such Third Parties; 5.1.6. the transfer of Personal Data to electronic signature services (if any) for signing documents while using the Platform; 5.1.7. the transfer of Personal Data to Third Parties in the cases and to the extent provided for by this Privacy Policy.
5.2. By agreeing to the terms of this Privacy Policy, the Client gives their Consent to: 5.2.1. the processing of their Personal Data by the Company for the purposes of registration on the Platform, creation and use of an Account, and provision of the Services; 5.2.2. the processing of Personal Data that the Client provides while making a booking, communicating with the Owner, and using other functional features of the Platform; 5.2.3. the processing and storage of documents and materials that the Client uploads or generates through the Platform (in particular photos, videos and other files, if applicable); 5.2.4. the processing of data automatically collected while using the Platform, to the extent necessary to provide the Services and ensure the security and stable operation of the Platform; 5.2.5. the processing of payment data and making payments through the payment service (payment infrastructure provider), as well as the transfer of the necessary Personal Data to such Third Parties; 5.2.6. the transfer of Personal Data to electronic signature services (if any) for signing documents while using the Platform; 5.2.7. the transfer of Personal Data to Third Parties in the cases and to the extent provided for by this Privacy Policy.
5.3. The Company has the right to obtain the User's Consent by way of the User performing a clear affirmative action on the Platform, in particular by checking the corresponding checkbox and/or clicking the "I Agree" button or a similarly worded text during registration, use of the Platform, or receipt of the Services.
6. STORAGE AND PROTECTION OF PERSONAL/STATISTICAL DATA
6.1. The Company uses all necessary security and protection measures for Data to ensure its confidentiality and prevent loss or unlawful disclosure.
6.2. The Company protects and stores Data against: 6.2.1. loss; 6.2.2. unlawful use, transfer, disclosure, modification, deletion and/or destruction.
6.3. The Company has the right to store the User's Personal and Statistical Data for 3 (three) years after termination of the relationship in the following cases: 6.3.1. for statistical accounting purposes; 6.3.2. if required by applicable law; 6.3.3. if necessary for conducting business; 6.3.4. for conducting marketing analytics.
7. GROUNDS FOR PROCESSING PERSONAL/STATISTICAL DATA
7.1. The Company processes Personal Data on the following lawful grounds (taking into account the Platform's model and booking/document functionality): 7.1.1. The User's Consent to the processing of their Personal Data, given during registration/use of the Platform and/or while using certain features (for example, verification, uploading documents/photos/videos, signing documents through an electronic signature service). 7.1.2. Conclusion and performance of transactions and taking actions preceding the conclusion of transactions at the User's request: in particular, provision of Services under the Public Offer between the Company and the User (creation of an Account, access to the Platform's functionality, communication, generation/storage of documents), as well as ensuring the booking process and documentation of the interaction between the Owner and the Client through the Platform. 7.1.3. The necessity to fulfill an obligation of the Company provided for by Ukrainian law (for example, responding to lawful requests from government authorities, complying with accounting/reporting requirements and other mandatory requirements, if applicable to the Company's activities). 7.1.4. The necessity to protect the legitimate interests of the Company and/or Users to whom Personal Data is transferred (in particular, ensuring the information security of the Platform, preventing fraud, reviewing complaints and disputes between the Owner and the Client within the Platform's functionality, protecting the Company's rights in the event of claims).
7.2. Where the basis for processing your Personal Data is your Consent, you have the right to withdraw it at any time. To withdraw your Consent, you may send an email to: info@loka.zone. If Consent is withdrawn, the Company has the right to stop providing Services and terminate all relations with you. If Consent is withdrawn, your Personal Data will be irrevocably deleted.
7.3. The Company undertakes to stop processing Personal Data within 2 (two) business days from the moment of receiving the withdrawal of Consent.
8. USER RIGHTS
8.1. The terms of this section apply to Users and relate to specific requirements under Ukrainian law, in particular the Law of Ukraine "On Personal Data Protection", and grant the User the following rights: 8.1.1. to receive information about the terms of granting access to Personal Data, in particular information about Third Parties to whom it is transferred; 8.1.2. to receive information, no later than thirty calendar days from the date of receipt of the request (except in cases provided by law), as to whether Personal Data is being processed; 8.1.3. to send a reasoned request objecting to the processing of Personal Data; 8.1.4. to send a reasoned request to change or delete Personal Data; 8.1.5. to the protection of Personal Data from unlawful processing and accidental loss, destruction, or damage due to deliberate concealment, failure to provide, or untimely provision thereof, as well as to protection from the provision of information that is inaccurate or defames the honor, dignity, and business reputation of the User; 8.1.6. to file complaints regarding the processing of Personal Data with a court; 8.1.7. to apply legal remedies in the event of a violation of personal data protection legislation; 8.1.8. to make reservations regarding restrictions on the right to process Personal Data when giving consent; 8.1.9. to withdraw consent to the processing of Personal Data; 8.1.10. to know the mechanism of automatic processing of Personal Data; 8.1.11. to protection from an automated decision that has legal consequences for them.
9. SUBMITTING A REQUEST
9.1. The User has the right to submit a request to the Company if they believe their rights have been violated, by sending a written request to the Company's email address: info@loka.zone.
9.2. The User's request must contain accurate information regarding the requirements to the Company. If the request does not specify precise requirements, the Company has the right to refuse to fulfil it.
9.3. The Company will not be able to respond to your request or provide you with Personal Data if it cannot verify your identity and establish that the Data belongs to you. If a request is received with inaccurate information and/or if it is impossible to verify the User's identity, the Company has the right not to process such a request and to contact the User for clarification. After receiving a response to the request for clarification, the User must submit a new corrected request or file a new request.
9.4. The Company is obliged to respond to the request or fulfil the conditions set out therein within 5 (five) business days from the moment of its receipt.
10. LIABILITY
10.1. The Company informs the User that the processing of Personal Data is necessary for the provision of Services through the Platform (including through Telegram). If the User disagrees with the processing of Personal Data on the terms of this Privacy Policy, the User may not use the Platform or receive the Services.
10.2. The Company is not liable if the User provides inaccurate, incomplete or outdated Personal Data, including if this results in the impossibility of creating/using an Account, providing Services, communication between the Owner and the Client, or generating/signing documents within the Platform.
10.3. The Company is not liable for the actions and/or the manner of processing of Personal Data by Third Parties engaged to ensure the operation of the Platform and its individual features, in particular: 10.3.1. payment services, payment infrastructure providers, crypto providers and/or crypto exchanges (if applicable); 10.3.2. electronic signature services (in particular Vchasno, Diia.Signature or other similar services, if applicable); 10.3.3. verification (KYC) services, in particular SumSub, which may be engaged to confirm a User's identity and/or verify the accuracy of the data provided (if applicable); 10.3.4. communication platforms/messengers (in particular Telegram), through which the User interacts with the Platform or the Company. 10.3.5. In such cases, Personal Data is processed in accordance with the privacy policies and terms of use of the relevant Third Parties.
10.4. The Company is not liable for the disclosure of a User's Personal Data to another User in cases where such disclosure was made by the User themselves (in particular by sending contact details in chat/messages) or is a consequence of using the Platform's functionality for interaction between the Owner and the Client within a specific deal.
10.5. The Company is not liable for: 10.5.1. failures, delays or the impossibility of using the Platform caused by the operation/limitations of third-party services or platforms (in particular Telegram, electronic signature services, payment services); 10.5.2. loss, unauthorized access to, or disclosure of Personal Data as a result of a hacking attack, a breach of the Platform, the User's device or the User's account on a third-party platform, or the unlawful actions of Third Parties; 10.5.3. the consequences of the User's use of the Platform in violation of the law or the terms of the documents governing use of the Platform.
10.6. Data transmission over the internet and/or through third-party communication platforms cannot be completely secure. Although the Company takes reasonable measures to protect Personal Data, the Company cannot guarantee the absolute security of its transmission, and the User independently bears the risks associated with the use of communication channels and services not controlled by the Company.
11. COOKIES
11.1. On the Platform, primary access may be carried out through Telegram. In such a case, the Company does not set cookie files directly within Telegram, and technical data may be processed by Telegram in accordance with its own rules and policies.
11.2. If the User uses the Platform's web interface (including web pages opened within Telegram), the Company may use cookies and/or other similar technologies to ensure the proper operation of the web interface, save settings, and enhance security.
11.3. The Company may use the following types of Cookie files (if applicable in the Platform's web interface): 11.3.1. session cookies, which operate during a single session of use and are usually deleted after the web browser is closed; 11.3.2. persistent cookies, which are stored for a defined period or until deleted by the User; 11.3.3. third-party cookies, which may be set if integrations/third-party services are used in the Platform's web interface (if any).
11.4. The User may manage cookie files through the settings of the browser used to access the Platform's web interface. If cookies are blocked or deleted, certain features of the Platform's web interface may work incorrectly or be unavailable.
12. AGE POLICY
12.1. The Company provides Services to persons who have reached the age of majority in accordance with Ukrainian law. The Company does not process the Personal Data of persons who have not reached such age.
12.2. The Company has the right to delete the Personal Data of a person who has not reached the age of majority without prior notice and without any consequences for the Company, and to stop providing Services to such a person.
12.3. The Company has the right to delete the Personal Data of a person who has not reached the age of consent without prior notice and without any consequences for the Company, and to stop providing Services to such a person.
12.4. If you have information about the receipt of Services by a person who has not reached the age of majority or the age of consent, please contact the Company's support service by sending an email to: info@loka.zone.
13. CHANGES TO THE PRIVACY POLICY
13.1. We have the right to periodically amend the Privacy Policy to ensure the security of Data and compliance with the requirements of Ukrainian law.
13.2. The User is obliged to read the new terms of the Privacy Policy, and the Company is not liable if the User fails to do so.
13.3. The Company updates the date of the current version of the Privacy Policy in the "Updated" line at the top of the document.
13.4. Our electronic copies of the Privacy Policy are deemed to be true, complete, valid, legally binding, and applicable at the time of your visit to the Website.
14. CONTACTS
14.1. The User has the right to contact the Company's support service at the email address: info@loka.zone, to exercise their rights in accordance with the terms of this Privacy Policy, in the event of their violation, and also to leave feedback or ask a question.
