Privacy Policy

Vortex (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how

your personal information is collected, used, and disclosed by Vortex.

This Privacy Policy applies to our website, and its associated subdomains (collectively, our “Service”)

alongside our application, Vortex. By accessing or using our Service, you signify that you have read,

understood, and agree to our collection, storage, use, and disclosure of your personal information as

described in this Privacy Policy and our Terms of Service.

Definitions and key terms

 Company: when this policy mentions “Company,” “we,” “us,” or “our,” it refers to individual developer account:

Vortex LLC that is responsible for your information under this Terms & Conditions.

 Country: where Vortex or the owners/founders of Vortex are based, in this case is Belarus

 Customer: refers to the company, organization or person that signs up to use the Vortex Service to manage

the relationships with your consumers or service users.

 Device: any internet connected device such as a phone, tablet, computer or any other device that can be used

to visit Vortex and use the services.

 IP address: Every device connected to the Internet is assigned a number known as an Internet protocol (IP)

address. These numbers are usually assigned in geographic blocks. An IP address can often be used to

identify the location from which a device is connecting to the Internet.

 Third-party service: refers to advertisers, contest sponsors, promotional and marketing partners, and others

who provide our content or whose products or services we think may interest you.

 Website: Vortex's site, which can be accessed via this URL:

 You: a person or entity that is registered with Vortex to use the Services.

Information automatically collected

There is some information like your Internet Protocol (IP) address and/or browser and device

characteristics — is collected automatically when you visit our platform. This information may be used

to connect your computer to the Internet. Other information collected automatically could be a login,

e-mail address, password, computer and connection information such as browser plug-in types and

versions and time zone setting, operating systems and platforms, purchase history, (we sometimes

information including page response times, download errors, length of visits to certain pages, page

interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse

away from the page. We may also collect technical information to help us identify your device for

fraud prevention and diagnostic purposes.

We automatically collect certain information when you visit, use or navigate the platform. This

information does not reveal your specific identity (like your name or contact information) but may

include device and usage information, such as your IP address, browser and device characteristics,

operating system, language preferences, referring URLs, device name, country, location, information

about who and when you use our and other technical information. This information is primarily

needed to maintain the security and operation of our platform, and for our internal analytics and

designated your mobile device (The Identifier for Vendors-IDVF) and Internet Protocol Address-IP

Address).

Data Categories and Data Types

 Contact Information: Phone number, e-mail address

 Process Security: Internet traffic data (network movements, IP address, visit data, time and date information),

device name, In-app purchase history, identifier for advertisers designated in your mobile device used in

accessing our services (if you give a permission, the Identifier for Advertisers-IDFA), identifier for

vendors/developers designated your mobile device (The Identifier for Vendors-IDVF)

 Customer Transaction: Order information

 Marketing Data: IDFA, IDVF

We may collect your Log Data generated while you are using our services/applications (through our

products or third party products). This Log Data may include information such as your device’s

Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app

when utilizing our service/application, the time/date of your use of the service/application, and other

statistics.

How We Use Your Information

We use your information for a variety of business purposes, including to provide our Services, for

administrative purposes, and to market our products and Services, as described below.

Provide Our Services

We use your information to fulfill our contract with you and provide you with our Services, such as:

 (a) Providing responses to your text messages and search queries, and other similar Services;

We use your information for various administrative purposes, such as:

 (a) Pursuing our legitimate interests such as direct marketing, research and development (including marketing

research), network and information security, and fraud prevention;

 (b) Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and

prosecuting those responsible for that activity;

 (c) Measuring interest and engagement in our Services;

 (d) Short-term, transient use, such as contextual customization of ads;

 (e) Improving, upgrading or enhancing our Services;

 (f) Developing new features and Services;

 (g) Ensuring internal quality control and safety;

We may use personal information to tailor and provide you with content and advertisements. We may

provide you with these materials as permitted by applicable law. Some of the ways we may market to

you include email campaigns, custom audiences advertising, and “interest-based” or “personalized

If you have any questions about our marketing practices or if you would like to opt out of the use of

your personal information for marketing purposes, you may contact us at any time as set forth in

Section 15 below.

Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable

law.

(a) Share Content with Friends or Colleagues. Our Services may offer various tools and

merger, sale, or asset transfer, as described below.

Disclosures to Provide our Services

The categories of third parties with whom we may share your information are described below.

 (a) Other Users or Third Parties: When you use the Services, you may choose to share personal information or

content with other users or third parties. In addition, certain aspects of your profile may be available to other

users.

 (b) Service Providers: We may share your personal information with our third-party service providers who use

that information to help us provide our Services. This includes service providers that provide us with IT support,

hosting, payment processing, customer service, and related services.

 (c) Business Partners: We may share your personal information with business partners to provide you with a

(and similar information collected from other services) for purposes of delivering personalized advertisements

to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-

based advertising” or “personalized advertising.”

 (e) APIs/SDKs: We may use third-party application program interfaces (“APIs”) and software development kits

(“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs,

please contact us as set forth below.

Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external

parties if we, in good faith, believe doing so is required or appropriate to: comply with law

enforcement or national security requests and legal process, such as a court order or subpoena;

 The law explicitly stipulates the process by which we process your personal data

reasonable time until the purpose of processing cease to exist, or during legal periods of limitation.

Vortex LLC may continue to store your personal data, even after the expiry of the purpose of its use

provided that it is required by other laws or a separate granted by you in this regard. In cases that you

allow Vortex LLC to store your personal data for additional time by giving your consent, such data

shall be immediately deleted, destructed or anonymized upon the expiry of such additional time or

once the purpose of processing no longer exists.

Anti-virus application

Suppliers can access Vortex LLC servers or systems through SSL-VPN defined on Firewalls. A

separate SSL-VPN identification has been made for each supplier; with the identification made, the

supplier only provides access to the systems that it should use or is authorized to use.

User identifications

Vortex LLC employees’ authorization to Vortex LLC systems is limited only to the extent necessary by

job descriptions; in case of any change of authority or duty, systemic authorizations are also updated.

Information security threat and event management

Events that occur on Vortex LLC servers and firewalls, are transferred to the “Information Security

Threat and Event Management” system. This system alerts the responsible staff when a security

threat occurs and allows them to respond immediately to the threat.

Two-factor authentication

Remote access to sensitive data is allowed through at least two-factor authentication.

Training

In order to increase the awareness of Vortex LLC employees against various information security

violations and to minimize the impact of the human factor in information violation incidents, trainings

are provided to employees at regular intervals.

Physical data security

It ensures that personal data on papers is necessarily stored in lockers and accessed only by

authorized persons. Adequate security measures (for situations such as electric leakage, fire, deluge,

thievery etc.) are taken based on the nature of the environment where sensitive data is stored.

Non-disclosure agreements are concluded with employees taking part in sensitive personal data

processing.

Transfer of sensitive personal data

If transfer of sensitive personal data is required through email; such transfer is done through (i)

encrypted corporate email or (ii) Registered E-mail In the event that the personal data is damaged as

a result of attacks on Vortex LLC Apps or on the Vortex LLC system, despite Vortex LLC taking the

necessary information security measures, or the personal data is obtained by unauthorized third

protection authority and takes necessary measures.

Transferring Personal Data to Third Parties

The procedures and principles to be applied for transferring of personal data are regulated in articles

8 and 9 of the PDP Law, and the personal and special categories of data of the supplier may be

transferred to third parties within the country or abroad since we may use servers and cloud systems

located abroad. Your personal data may be transferred abroad for the following reasons

 Conducting storage and archive activities

 Sharing identity, communication and transaction security information with authorized public institutions and

organizations for the purpose of execution of activities in compliance with legislation, monitor and execution of

legal affairs, informing authorized persons, institutions and organizations.

 Sharing identity and contact information to manage after-sales support services, conduct business activities

and manage customer relationship management processes.

 Sharing identity and contact information, by user to third party applications which are integrated to the Vortex

LLC Apps with the explicit consent of the User.

Personnel

If you are a Vortex worker or applicant, we collect information you voluntarily provide to us. We use

the information collected for Human Resources purposes in order to administer benefits to workers

and screen applicants.

We reserve the right to transfer information to a third party in the event of a sale, merger or other

transfer of all or substantially all of the assets of Vortex or any of its Corporate Affiliates (as defined

herein), or that portion of Vortex or any of its Corporate Affiliates to which the Service relates, or in

the event that we discontinue our business or file a petition or have filed against us a petition in

bankruptcy, reorganization or similar proceeding, provided that the third party agrees to adhere to the

terms of this Privacy Policy.

We may disclose information (including personal information) about you to our Corporate Affiliates.

For purposes of this Privacy Policy, "Corporate Affiliate" means any person or entity which directly or

indirectly controls, is controlled by or is under common control with Vortex, whether by ownership or

otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by

The laws of Belarus, excluding its conflicts of law rules, shall govern this Agreement and your use of

the app. Your use of the app may also be subject to other local, state, national, or international laws.

By using Vortex or contacting us directly, you signify your acceptance of this Privacy Policy. If you do

not agree to this Privacy Policy, you should not engage with our website, or use our services.

Continued use of the website, direct engagement with us, or following the posting of changes to this