Privacy Policy

Last updated: October 18, 2018

We respect your privacy and care about keeping your personal information safe. This Privacy Policy
will provide you with all the details of the ways in which your data is used. You will also get to know
the rights that you are entitled to and and how the applicable regulations protect you and your
personal information. Please make sure to read this Privacy Policy carefully before you start using our
services.

In our Privacy Policy:

Services mean every product, service, content, functionality, technology or function, all affiliated
websites and applications that we offer.

Portal means the websites, applications and mobile sites or other online content through the agency
of which we offer our services.

1. Who are we?

The main administrator of your data in the extent of providing our international services is the
TuneFORCE company with its registered office in Poznań 60-003, Krzeszowicka 25. The
aforementioned entities from Zeremi.com are considered administrators of personal information
affiliated with services that they offer on the local markets.

The administrator of your personal information used in connection with services provided by the
international Portal is: TuneFORCE company in Poznań 60-003, Krzeszowicka 25.

The the TuneFORCE company is entered into the Register of Entrepreneurs run by the Regional Court
in Poznań and is identified by the following numbers: NIP 8862639661, REGON: 021163970.

The applied contact data is introduced in Section 13.

2. What types of information about you do we collect?

2.1.1 Information provided directly by yourself

Registration and other information in regards to your account

For the purpose of using our services, we may collect the following information about you during the
registration process:

- email address used for the registration process
- phone number which the user gives when placing an offer
- city or country of the origin of the advertisement, which the user gives when placing an offer

It is compulsory to present the information above in order to use the services offered by keeping an
account on Zeremi.com portal and for the purpose of placing advertisements on the portal.

When using our services, you can also voluntarily provide the following personal information:

- first and last name;
- email address;
- phone number;
- your PayPal account information in case you are interested in purchasing our paid services as
determined in the Rules and Regulations;

Communication via chat function in our portal

When you use the chat function to communicate with our staff or representatives, we collect the
content of the messages and the information that you provide by using this functionality.

Communication via email and correspondence

In case of contact via email we collect all the information that you share in the correspondence with
our staff or representatives.

2.1.2 Data that we automatically gather when you are using our services

When you are using our Portal we automatically collect the following information:

Device data

We gather information regarding your device in terms of version of the operating system and unique
identificators. An example of this type of information is the name of your mobile network operator.
We connect the data about the device to your account on Zeremi.com.

Localization data

Considering the privacy settings of your device, when you put a product on sale on our portal, we
automatically collect and use the information about your current localization. We use various
technology to determine your localization, including IP address, GPS, Wi-Fi access points and mobile
network stations. Your current localization enables displaying and browsing products put on sale in
your neighborhood and help you sell products in your area.

Log-in data

We collect technical details, including Internet Protocol (IP) address of your device, time zone and
operating system information. We also store information about your log-ins (registration date, the
date of last password change and last successful log-in) as well as type and kind of your Internet
browser.

Activity in portal data

We collect information about your activity in the portal, among which is the information about
websites which directed you to our portal, date of each visit, result of your searches, lists of products
and advertisement banners you clicked, your interaction with this type of ads and product lists,
duration of your visit and also the order of visiting sections of our portal.

Cookies

We use cookies in order to manage user sessions, store language preferences and showing you
personalized ads. "Cookies" are small text files transferred by Internet server to the hard drive in
your device. Cookies can be used to collect information about the date and time of your visit, history
of search, your preferences and user name. You can manage the settings of your browser to deny all
or some of the cookies or set warnings to inform you about sites using cookies. Remember that if you
block or deny cookies, some of our services or parts of our portal may not be available for you or
they may work improperly. For any additional information about the way we use cookies please
become acquainted with our Cookies and Similar Technologies Policy.

2.1.3. Data collected from third parties or from publicly available sources

We receive your personal information from various third parties (and public sources) the type of
which is listed below:

1) Some information of technical matter or resulting from the way of use, collected from
analytical service providers, e.g. Google.
2) Contact details connected to commercial activity collected from informative sources e.g.
credit information agency and subjects building base of potential contractors, as well as
publicly available registers (e.g. Commercial Activity Central Evidence and Information
Center).
3) Other users of the portal in the scope of their correspondence regarding our services or
transactions that you run with them (e.g. proof of issue, information about product’s
inconsistency with its description, information about potential fraud).

3. Do we collect data from children?

Our services are not directed to children below 16 years of age and we do not knowingly collect data
from them. If we learn that a person below 16 years of age provided us with their personal
information we will delete it immediately.

4. Why do we process your information?

We will only use your personal information when it is allowed by law. We use your personal
information most frequently when:

1) It is mandatory to create or perform an agreement (remember that by using our services you
enter an agreement on Electronic Provision of Services).

2) It is mandatory for the purposes resulting from our lawfully principled interests aiming at
improving our services and providing you with access to a safe and properly working portal. It
is compulsory

3) It is compulsory for us to perform our lawful liability

4) In some circumstances we may also process your personal information based on the
acceptance that you provided. In those conditions we will educate you about the purpose of
processing and the category of the used data.

Below presented is the description of the ways of how your personal information is used and legal
bases upon which we have built our actions. Furthermore, when it is applicable, we identify and
describe our lawfully principled interests.

4.1 Processing for the purpose of ensuring access and providing services via this portal

a) When you log in with your identification email we will use your first and last name, your
phone number or email address in order to identify you as a user and give you access to our
portal.

b) Log-in information above we also use to provide you with services according to our Rules and
Regulations.

c) We use your email address to send you offers and recommendations of our services which
you might find interesting.

d) Aforementioned information is processed for the purpose of proper performance of the
agreement that you entered and based on lawfully principled interest in the event of taking
marketing actions aimed at offering you our services.

4.2 Processing in order to improve the comfort of using the portal

We manage user activity data (e.g. sequences of clicking within the portal) to:

a) offer you personalized content as in better search results when using our services;

b) assess the duration and ways of navigating within our portal for the reason of getting to
know your preferences and improving our services - for instance, based on the content that
you find interesting we can suggest other materials you may like;

c) monitor and report the effectiveness of marketing campaigns to our business partners and
for inner business analyses purposes;

We use geo-location data for the following purposes:

a) connecting anonymous and aggregate information about characteristics and activity of
Zeremi.com’s users including purpose of business analytics, segmentation and developing
anonymous profiles;

b) supporting the development of our portal and personalizing the content directed to you - for
instance, with the help of geo-location and for offering you more comfort of purchasing, we
can display lists of announcements from your nearby area;

c) measuring and monitoring your interactions with advertisement banners of third parties,
that we put in our portal.

d) Based on the information about log-in’s which contain your identification email, we
recognize various devices (as computer, mobile phone, tablet etc.) used to gain access to the
portal. It allows us to integrate your activity within our portal on all of your devices and helps
us to provide you with identical comfort of browsing our portal no matter which device you
are using.

We process the aforementioned information based on premise of our lawfully principled interest in
order to improve the comfort of your interaction with our portal and for the due performance of the
agreement you entered into.

4.3 Processing for the purpose of keeping the portal safe and secure

We use log-in data and unique identification of devices to administrate and protect our portal
(including diagnostics, data analyses, tests, prevention from abuse, keeping IT systems, support,
reporting and hosting of data).

a) We analyze your communication via email to prevent abuse and promote safety by blocking
spam or offensive messages which might be sent to you by other users.

We process the aforementioned information for the due performance of the agreement you entered
into, to improve the comfort of your interaction with our portal and based on premise of our lawfully
principled interest in preventing abuse.

5. How will we notify you about changes in our Privacy Policy?

Privacy Policy may be altered or updated by us. Any changes will be announced on this page,
additionally we will inform you via email or within our portal. If you do not consent to introduced
changes you have the right to close your account by going into account settings and choosing the
option of closing your account.

6. Your rights

Prevailing regulations regarding protection of privacy guarantee you with rights connected with
processing your personal information. The type of our actions decide about the scope of your rights.

If you want to exercise any of the rights mentioned below, go into your account/privacy settings or
contact us via the Contact Form.

Right to access your personal information. This enables you to receive information about processing
your personal information and receive copy of your personal information that we use. This right
allows you to verify if your data is used compliant to law.

Right to correct your personal information. This enables you to request correction of incomplete,
untrue or out-of-date data that we use. In some circumstances while handling your request we will
have to verify the accuracy of the personal information that you provide.

Right to limitation of processing your personal information. This enables you to request to stop using
your data in the following situations: (a) when you would like us to check the accuracy of the data;
(b) when our use of your data is against the law; (c) when you need the data to determine or defend
claims even when we no longer need your information for our processing purposes; (d) when you
have raised objections against our ways of using information but we have to verify if we still have
prevailing and legally justified basis to continue using your personal information.

Right to erase your personal information. This enables you to request to erase your personal
information provided it is no longer needed for the purposes it was collected before. You can also ask
to erase your personal information in case you have successfully used your right to object processing
of your personal information (see below), if we use your data against the law or we are obliged to
erase your personal information to fulfill our legal obligation indicated in the regulations of
applicable law. Please remember that in some circumstances we are obliged to use your personal
information based on the applicable regulations and therefore cannot fulfill your request. You can
find out more about this matter in Section 10.

Right to object processing of your personal information in situation when we use your data based on
the premise of legally principled interest (of ours or third parties). The right to object can be used
based on causes connected to your special situation when in your opinion the processing of data
violates your rights or freedom. You are also allowed to use this right if we process your personal
information for the purpose of direct marketing. In some cases we can prove that we have all legally
justified bases to process the information which are prevailing to your rights and freedom (e.g. the
necessity to ensure safety for the portal and prevention of fraud). In those cases the right to object is
not linked to erasing your personal information.

Right to transfer your personal information. Fulfilling this right we will deliver to you or a third party
of your choice your personal information in a structured, commonly used format suitable to machine
reading. Please remember that you are only entitled to this right in reference to personal information
used on the basis of acceptance that you provided or the premise of fulfilling the agreement you
entered into and the sole use of data is handled automatically (in IT systems)).

In situation when you have consented us to use your personal information, you have the right to
revoke it at any moment. Revoking of your consent does not influence the agreement to the right to
process information which has been made according to the consent before its revoking.

Implementation of the rights is, as a rule, free of charge: You are not expected to issue payments for
realization of the right to access to your personal information (or realization of any other right). We
can, however, request payment in a reasonable amount if your request is unfounded and excessive in
an evident way, especially in consideration with its constant character. In such cases we can also dey
fulfilling your request.

Execution time of your request: We will make sure to answer to all legally justified requests in the
time of one month. If your request is particularly complicated or you submitted numerous requests
the identification process may take more time than one month. In such case we will inform you of
prolonging the execution process and provide you with the current information regarding realization
of your request.

You also have the right to file a complaint at any given time to the appropriate supervisory body
according to the information found in Section 13.

We will be grateful if you give us a chance to handle your request and doubts regarding our activities
before you turn to supervisory body. For this reason please contact our Privacy Department via
contact form.

7. Communication and Marketing

We are going to contact you via email or notifications according to our services and portal. The
communication will be aimed at confirmation of your registration, informing you when your
advertisement becomes active/ends and in case of other transaction messages connected to our
services. Considering that sending you this type of notifications is necessary from our perspective,
you may not be able to resign from receiving them.

However, you can resign from receiving marketing communication by reporting this request via
contact form or via email address: info@zeremi.com. If you meet any problems or difficulties please
contact us directly via contact form.

You will receive marketing communication when:

- you expressed the will to receive such information by accepting marketing communication;
- you provided your personal information taking part in a contest; or
- you took part in a promoting campaign

8. Who do we share your information with?

For executing aims specified in Section 4 we may share your personal information with the following
category of receivers:

Affiliated companies: We may share data with other companies with their registered offices outside
European Economic Area, who help us provide services connected with business activity run by us.
The mentioned services are meant to improve the products, support the customers and create the
mechanism to search for abuse. Each case of personal data sharing with companies situated outside
the European Economic Area within the portal Zeremi.com is happening with assurance of crucial
safety protection means specified in Section 9 or is a subject of the agreement of data sharing which
clearly specifies obligations of both parties as well as ensures the right technical and organizational
resources used to keep your personal information safe and secure.

Third parties providing services: We use the services of third parties which help us provide particular
solutions connected to our services, e.g. storing data in the cloud of Digital Ocean Services and
Microsoft Azure. Providers of such services may have their headquarters both in the European
Economic Area and outside of it.

We check and control our providers and require them to ensure the safety of your personal
information as well as using it accordingly with law. We do not allow our providers to use your data
for their own purposes. Within the framework of cooperation we reserve that the providers are only
allowed to use your personal information in particular ways, compliant with our rules and
instructions.

Marketing and analytical services providers: To improve our services, sometimes we share
information about you in form that makes providers unable to identify you for the purpose of
analysing the ways in which users wield our services/portal. For the purpose of monitoring and
reporting the effectiveness of our business partners’ campaigns and for inner business analyses we
share information with them in a way that they are unable to identify users. You will find out more
about our analytical service providers in our Cookies and Similar Technologies Policy.

Law enforcement authorities, supervisory authorities and other: We may reveal your personal
information to law enforcement authorities, supervisory authorities, public authorities, subjects
executing public duty or working for the public authorities and other third parties. Revealing such
information takes place in compliance with executing legal obligation.

We may decide to sell, transfer or merge a part of our company or our assets. We may also seek to
acquire or merge with other companies. In the event of any changes, the new owner will be able to
use your personal information in ways specified in this Privacy Policy.

Publicly available information: If you are using our services and decide to put a given item up on sale,
you can decide to make some personal information public for other users of the portal Zeremi.com.
This information may include your first and last name, email address, your location and phone
number. Please remember that information that you make public for other users can be passed on,
therefore you should be very careful.

9. Sharing data with third countries

In the event of sharing your personal information outside of the European Economic Area we
guarantee that the level of security is alike by introducing at least one of the protections below:

We will only share data with countries that the European Commission found as providing satisfactory
level of personal information security. Here you will find more details: European Commission:
Adequacy of the protection of personal data in non-EU countries

Using services of given providers we can wield agreements justified by the European Commission
which ensure that level of personal information security is alike in the European Union. Here you will
find more details: European Commission: Model contracts for the transfer of personal data to third
countries

If our providers have their headquarters in the United States of America we can share information if
they are encompassed within the program Privacy Shield, which obliges them to ensure similar
information security regarding data shared between Europe and the United States. Here you will find
more details: European Commission: EU-US Privacy Shield

10. Where and how long do we store your personal information?

Information that we store will be stored and processed both within the European Economic Area and
outside of it, on properly secured servers, for the purpose of providing our users with the best quality
service, e.g. high speed websites or constantly developing mobile apps.

We store your data for as long as it is necessary to realize aims for which it was collected, including
execution of our legal obligations, tax and bookkeeping or for reporting purposes.

In order to assess the proper retention period of personal information, we include the quantity and
type of processed data, taking into account the type of data in a particular category. We also take
into consideration the potential risk of prohibited use or unauthorised disclosure of your information,
possibility of realization aims with the help of other means and the regulations referring to the use
and processing of personal information.

Your personal information affiliated with an account on Zeremi.com is stored during its existence in
the portal for the purpose of providing services accordingly to the Rules and Regulations as well as
marketing purposes.

After closing your account we may store your data for as long as it is necessary to realize aims for
which it was collected, including execution of our legal obligations or our lawfully justified interests
(e.g. to prevent abuse).

Personal information used within advertisements are stored for the period of 6 months from the day
of the advertisement’s expiry.

Messages sent within the portal are stored for 120 days.

Personal information connected with technology of cookie files are stored for the period equivalent
to the lifecycle of cookie files or until their deletion by the user.

If you have any questions regarding retention periods of your personal data, please contact us via
contact form.

11. Technical and organizational means, and the security of processing

All personal information is stored on properly secured servers. We have implemented the right and
necessary technical and organizational means that serve the protection of your data. Zeremi.com is
constantly rating the degree of safety within its site and monitoring inner regulations and procedures
designed to (a) protect information from accidental or against the law loss, unauthorised access or
disclosure, (b) identify risk for the security of Zeremi.com and (c) minimize the danger for security
including regular tests and making risk assessments. Additionally, we ensure that all information in
regard to payment are ciphered using the SSL technology. Please remember that despite effort put to
protect your personal information, sharing information within the Internet or public web is never
completely safe and there is risk of your information being possessed by unauthorised third parties.

12. References to websites of third parties

Our portal may contain references to websites of third parties or their applications. If you click on
one of those references remember that each site you are going to be directed to has their own
Privacy Policy. We have no influence on such websites/applications and are in no way responsible for
their policies. We encourage you to acquaint yourself with information about Privacy Policy each
website you visit when leaving out portal.

13. Contact

If you need more information or realization of your rights please contact our Privacy Department via
contact form.

14. Supervisory authorities

For local cases connected to protection of personal information you can contact the President of the
Office for the Protection of Personal Data:
Stawki 2, 00-193 Warszawa