Privacy Policy

This Policy is part of the User Agreement, by accepting which (acceptance of the offer), the User agrees to the processing of personal data according to the terms and conditions set forth below.

This Privacy Policy applies to personal data that ster and/or its affiliates (hereinafter referred to as " We", " Us", "Our", "Ours" or "ster") may obtain about any User (hereinafter referred to as the “User”, "Users", " you", "your", or "yours") of the ster mobile application (hereinafter referred to as the “Application” or "application") during the use of ster products.

By registering or being in ster, the User consents to the Privacy Policy and agrees to the terms and conditions for processing personal data specified herein.

Use of the Application signifies the user's unconditional acceptance and consent to the terms and conditions of the Privacy Policy and the conditions for processing information received from the User's device specified herein. You agree to stop and refrain from using the Application if you disagree or do not accept this Policy.

1. Who Processes Information?

This Privacy Policy applies exclusively to the application, and does not apply to the ster websites, which do not contain this Privacy Policy and do not have links to it, or to websites and applications that have their own Privacy Policy.

Ster is committed to ensuring that your personal data is protected during processing. We recommend that you review this Privacy Policy regularly, as it may be updated to comply with legal requirements or changes to ster's internal processes. We have the right to amend this Policy by posting a new version of the Policy in the Appendix and/or on the website with or without notice. The User carries all obligation to be familiar with the most up-to-date version of this Policy.

2. Actions Performed With Personal Data

In the process of processing the User's personal data using automation tools, ster performs the following actions: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.

3. What Data Does Ster Collect About You?

Ster receives the following data, using the methods listed below:

3.1. When registering with ster:

• Cell phone number.
• Last name.
• First name.
• Address of legal residence.
• Copies of pages of your passport.

3.2. When transferring funds or replenishing the balance of your account: This data is not processed or stored by ster, but is transferred directly to acquiring:

• Bank card number from which deposits or transfers are made.
• Bank card expiration date.
• CVV/CVC/CVP of this card.

3.3. Refunds:

• Banking details.

3.4. Information that is transmitted automatically when interacting with ster

• Duration of the user session.
• Entry points (third-party resources that directed the user to the Application).
• Exit points (links in the Application through which the user goes to third-party resources).
• Country.
• Region, province, state or other subdivision of the country.
• Internet service provider.
• List of languages supported by the device.
• Type of operating system.
• Screen settings.

3.5. List of information that can be obtained from the User's device when using the Application and the purpose of obtaining it:

• The location information of the user's device (based on the data of the cellular operator's network and GPS signals) is used to determine the availability of the Application in the region.
• Photographic images obtained using the device's camera, or those stored in memory, are used as part of the services implemented in the Application, including supporting documents, which are used for registration and execution of operations and transactions.
• Mobile device information, such as device model, operating system version, unique device identifiers, as well as mobile network data and mobile phone number, are used to analyze possible errors in the operation of the Application and improve the operation of the Application.
• Information about the transactions and operations performed, such as the place, time and the amount of funds performed operation, the payment method, data on the seller and/or service provider, as well as other information related to the performance of the aforementioned operations, is used within the services implemented in the Application. Information about the performed operations, such as location, time and amount of completed transactions, payment method, seller and/or service provider as well as other data connected to the aforementioned, is used within the scope of providing services, implemented in the Application.

4. Analysis Tools

Ster uses Google Analytics to examine user activity.

Ster uses Google Analytics, which is a web analysis tool of Google Inc., Parkway Amphitheater, Mountain View, CA 94043, USA (“Google”) to facilitate the continuous improvement of our website. Google Analytics works with cookies and creates pseudonymous usage profiles that allow us to analyze your use of our website. The information stored in such cookies (e.g. browser type and/or version, operating system used, referrer URL, host name of the computer accessing, time of the server request) is typically transmitted to and stored on Google servers. To facilitate deactivation, you can also download and install the browser add-on from https://tools.google.com/dlpage/gaoptout?hl=en. More information is available in Google's Privacy Policy: https://policies.google.com/privacy?hl=en

5. Purpose Of Processing Personal Data

Ster processes personal data to fulfill the User Agreement. In particular, personal data is used for the following purposes:

• Granting the user access to ster.
• Facilitating continuous improvement and optimization of service quality of ster.
• Communicating with the User, sending notifications, requests and other information related to the work of ster.
• Protecting users from fraudulent activities.
• Distributing promotional materials and in marketing campaigns.
• Providing advertising and offers based on the User's preferences.
• Collecting, processing and presenting statistical data, big data and other studies.
• Studying the behavior of Users of the Application.
• Attracting new users.
• Verifying and confirming the User's identity for authentication and transaction processing.
• Transferring the User's data to Acquiring for account replenishment.

6. Legal Grounds For Processing Personal Data

We process the User's personal data if, and only if:

• The User has consented to his personal data being processed as provided for in the agreement; or
• The processing of the User's personal data is necessary to fulfill the concluded agreement between the User and ster; or
• The processing of the User's data is required by applicable law, a court decision or other qualified state or municipal authority.

7. Principles Of Data Protection

Ster endeavors to conduct its service such that the processing of personal data is minimized. In some cases, ster is obligated to transfer the User's personal data to third parties in accordance with the legal requirements. This, for example, occurs when there is reason to suspect that a crime has been committed or that our website and/or mobile application are being misused.

This Policy applies only to the application. Ster does not control and is not responsible for the information transmitted by the user to a third party, if such transmission was made on a third-party resource, which the user could have accessed via links in the Application, nor is ster responsible or for the consequences thereof.

Ster may engage third parties to provide certain services. If such entities, legal or otherwise, require access to personal data, ster shall restrict the transfer of personal data to that strictly necessary for the provision of the relevant services. In addition, such external service providers must independently comply with all applicable data protection regulations and laws.

For the purposes set out in this Policy, ster may employ partners with whom ster has concluded appropriate confidentiality agreements to process User information. The transfer of anonymized data regarding the use of the Application to partners for the purposes of improving the operation of the Application is carried out on the basis of relevant agreements with partners.

Ster takes all organizational and technical measures to protect the User's Information from unauthorized access, use, copying and distribution by third parties.

Information about the User may be provided to state authorities in accordance with relevant legal requirements.

8. Recipients And Legal Basis For Data Transfer

We disclose restricted information only as follows:

• Within ster. The User's personal data may be used by ster employees only as necessary for the purposes described above.
• Ster may also share your data with Third Party Service Providers. They will process your personal data as data processors (as outlined in Article 28 of the GDPR) exclusively on behalf of ster. The categories of such recipients may include: web analytics, data processing, advertising, email newsletters, payment processing, and other services. In such cases, Third Parties are required to comply with our privacy and data security requirements and may not use the personal data they receive from ster for other purposes. When ster discloses information to entities outside of the European Economic Area, it does so on the basis of the standards set forth in the European Commission-approved standard contractual clauses governing the transfer of personal data, as well as ster's own high standards of data security and respect for your privacy.

9. Storage And Processing Of User Personal Data

Personal data will be stored in accordance with the legal requirements of the countries where the Third Parties involved in the provision of services to the User are located.

According to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC: The term “personal data” is also defined as any information relating to an identified natural person; this term explored further in paragraph 4, section 1 of the same:

“… any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”

10. Personal Information Retention Period

Ster will retain your personal data for as long as necessary to achieve the purpose for which it was collected or comply with legal and regulatory requirements.

11. Your Rights And How To Exercise Them With Respect To Personal Data

You have the following rights with respect to your personal information:

The right to be informed - You have the right to receive clear, transparent and understandable information about how we use your personal data and about your rights.

Right to access - This right allows you to obtain a copy of the personal data we process and to verify that we process it in accordance with applicable legal requirements.

Right to amend - You can request changes to your personal data in the "My Profile" section.

Right to restrict processing - You can request that we suspend the processing of your personal information, for example, if you want us to establish the accuracy or the reason for processing your personal information.

Right to data portability - You can ask us to transfer your personal data. We will provide you or a third party of your choice with your personal data in a structured, standard, machine-readable format.

Right to object - You can object to the processing of your personal data at any time, if such processing is in our legitimate interests.

Right to withdraw consent to data protection - If you withdraw your consent, we will not be able to provide you with access to certain features of our website. We will inform you of this in the event and at the time of withdrawal of your consent.

Right to file a complaint - You have the right to contact your country's data protection authority to challenge our data protection and privacy practices.

Right to deactivate cookie files - If you would like to restrict or block all cookies used by our websites, please use the tool available on the relevant website or refer to your browser's instructions to learn how to manage your browser settings.

Right to be forgotten - You can contact support to request that your data be deleted from ster, if for any reason your data may harm you. This applies to outdated, inappropriate, incomplete, inaccurate or redundant data or information, the legal basis for the storage of which has disappeared over time. This right is exercised under certain conditions, and in turn ster endeavors to do everything necessary to ensure that your data is used only when necessary, and only in accordance with the stated purposes.

If you want to exercise these rights, write to support@ster.me at any time. We strive to respond to all legally valid inquiries within 30 days.

AT THE SAME TIME, THE WITHDRAWAL OF YOUR CONSENT TO THE PROCESSING OF PERSONAL DATA OR THE EXERCISE OF THE RIGHT TO BE FORGOTTEN ENTAILS THE DELETION OF THE ACCOUNT, WHICH MAKES IT IMPOSSIBLE TO USE ster. The rights provided for above are void where prohibited by law.

12. Amendments To The Privacy Policy

Ster has the right to amend this Privacy Policy. The new version of the Policy shall enter into force upon being posted unless otherwise specified therein.

13. Feedback

Questions or comments regarding the Policy can be sent to the email address: support@ster.me