This Privacy and Personal Data Processing Policy (hereinafter referred to as the "Policy") sets out the procedure for processing personal data and other information relating to users of the votway.com website, personal account, order forms, balance, support service and other functions of the Votway service.
This Policy shall apply together with the Votway Terms of Service and the Votway Refund Policy. Terms not defined in this Policy shall have the meanings assigned to them in the Terms of Service.
Use of the Website, registration of an account, placement of an Order, addition of funds to the balance, payment for Services, provision of a link to a Promotion Target, contacting the support service or continued use of the Service means that the User has read and understood this Policy.
This Policy does not replace separate consent to the processing of personal data where such consent is required by applicable law or by the rules of a payment partner.
1. General Provisions
1.1. The personal data controller is the person managing the Votway Service and specified in Section 15 of this Policy.
1.2. This Policy applies to all information received by the Operator about Users when they use the Website, register an account, place Orders, pay for Services, contact support, participate in security checks, request refunds or perform other actions within the Service.
1.3. The Operator processes personal data fairly and only to the extent necessary for the operation of the Service, provision of digital SMM services, performance of the Terms of Service, processing of payments, protection of the Operator’s rights, prevention of abuse and compliance with legal requirements.
1.4. The Operator does not request passwords for accounts on social media platforms, two-factor authentication codes, seed phrases, PIN codes, CVC/CVV codes, full bank card details or other sensitive payment information. Where such information is entered during payment, it is entered on the side of the payment aggregator, bank or payment system.
1.5. The User must not provide personal data of third parties through the Website or support service without a lawful basis.
2. Key Definitions
2.1. Personal Data means any information relating to an identified or identifiable User.
2.2. Processing of Personal Data means any operation performed on personal data, including collection, recording, storage, updating, use, transfer, anonymisation, restriction, deletion and destruction.
2.3. User means any person who visits the Website, registers an account, places an Order, adds funds to the balance, pays for Services, contacts support or otherwise uses the Service.
2.4. Payment Aggregator means a bank, payment service, payment system, processing centre or other third party that facilitates the acceptance of payments, refunds, anti-fraud checks and other payment-related operations.
2.5. Technical Data means information about the device, browser, IP address, cookies, actions performed on the Website, visit time, security events, logs and other parameters necessary for the operation of the Service.
3. Data That May Be Processed by the Operator
3.1. The Operator may process information voluntarily provided by the User when using the Service, including:
- username, email address, password stored in a technically secured form or other authentication data;
- personal account information, account settings and information required to communicate with the User;
- links to Promotion Targets, Order parameters, quantities, rates, comments, selected Services, statuses and Order history;
- support requests, correspondence, attachments, screenshots, descriptions of issues, Order numbers, transaction dates and other information required to review a request;
- information voluntarily entered by the User in forms, tickets, comments, promo code forms, affiliate programmes or other Service features.
3.2. The Operator may automatically receive and process Technical Data, including:
- IP address, date and time of visit, time zone, referral source, pages visited and actions performed on the Website;
- device type, operating system, browser, language, screen resolution, user agent and other device parameters;
- cookies, technical session identifiers, authentication data, security logs and error reports;
- anonymised or aggregated analytics data used to improve the Website, interface, stability and security.
3.3. When processing payments, refunds, chargebacks, anti-fraud checks or accounting records, the Operator may process financial and technical data received from a Payment Aggregator, bank or payment system, including:
- payment number, transaction identifier, amount, currency, payment status, date and time of the transaction;
- payment method in anonymised or partially displayed form, such as the type of payment instrument or the last digits of a bank card, where such information is provided by the aggregator;
- information relating to refunds, disputed transactions, anti-fraud checks, holds, fees, payment errors or chargebacks;
- other information necessary to confirm a payment, perform an Order, issue a refund, resolve a dispute and comply with the requirements of a payment partner.
3.4. The Service does not store full bank card details, CVC/CVV codes, PIN codes, one-time passwords or other sensitive payment information where such information is entered on a secure page of a Payment Aggregator, bank or payment system.
3.5. The Operator may receive data from third parties where necessary for the operation of the Service, including Payment Aggregators, banks, partners, contractors, hosting providers, anti-fraud systems, analytics services, support services and other technical providers.
3.6. The Operator does not intentionally process special categories of personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, intimate life or biometric personal data. If the User voluntarily provides such information through the support service or Website forms, the Operator may delete it or disregard it when reviewing the request, unless its processing is required by law.
4. Purposes of Data Processing
4.1. The Operator processes User data for the following purposes:
- registering, authenticating and maintaining the User’s account;
- providing access to the personal account, balance, Service catalogue and order form;
- placing, checking, launching, performing, restarting, cancelling and monitoring Orders;
- accepting payments, confirming payments, crediting funds to the balance, processing refunds and chargebacks, carrying out anti-fraud checks and maintaining accounting records;
- handling support requests, identifying Orders and resolving technical issues and disputes;
- preventing fraud, use of third-party payment instruments, spam, technical attacks, abuse of refunds, affiliate programmes and chargebacks;
- confirming that Services have been provided and protecting the rights and legitimate interests of the Operator, Users, partners and payment systems;
- complying with the requirements of applicable law, payment systems, banks, Payment Aggregators and authorised public authorities;
- improving the interface, Service quality, performance, security and ease of use;
- sending service notifications relating to registration, Orders, payments, refunds, security, amendments to legal documents and operation of the Service.
4.2. Marketing communications shall be sent to the User only where the relevant consent or another lawful basis exists. The User may unsubscribe from such communications using the available method where marketing communications are used by the Service.
5. Legal Bases for Processing
5.1. Depending on the circumstances, data may be processed on one or more of the following legal bases:
- performance of the Terms of Service and related documents;
- actions taken by the User for the purpose of registration, placement of an Order, payment for Services or contacting support;
- the User’s consent where required by applicable law;
- compliance with legal, payment system, banking, tax and accounting requirements;
- protection of the Operator’s rights and legitimate interests, including prevention of fraud, technical attacks, unjustified chargebacks and other abuse;
- the need to ensure the security of the Service and confirm that Services have been provided.
5.2. Withdrawal of the User’s consent shall not affect the lawfulness of processing carried out before the withdrawal and shall not prevent further processing where it is necessary for the performance of an agreement, compliance with legal requirements, protection of the Operator’s rights, resolution of disputes, processing of refunds, anti-fraud checks or accounting.
6. Cookies, Analytics and Technical Tools
6.1. The Website may use cookies and similar technologies for authentication, session storage, operation of the shopping cart or order form, prevention of abuse, analytics, interface improvement and proper functioning of the Service.
6.2. Cookies may be strictly necessary, functional, analytical or advertising cookies. The User may restrict or delete cookies through browser settings; however, this may cause certain Service features to function incorrectly.
6.3. The Website may use web analytics services, including Yandex Metrica, Google Analytics or similar tools, where such tools are enabled on the Website. These services may collect anonymised or technical information about visits, actions performed on the Website, devices, referral sources and other events.
6.4. Where the Website uses feedback forms, online chat, a ticket system, support widgets, anti-spam tools, anti-fraud tools or other technical modules, such tools may process information necessary for their operation.
7. Payment Aggregators and Payment Security
7.1. Payment for Services may be made through third-party Payment Aggregators, banks, payment systems, payment links, electronic wallets or other methods available on the Website or payment page.
7.2. Where the relevant payment services are integrated, payments may be processed through YooKassa or similar Payment Aggregators. The exact list of available payment methods is determined by the Operator and/or payment partner and displayed on the Website or payment page.
7.3. During payment, the User may be redirected to the website or interface of a Payment Aggregator, bank or payment system. Such third parties may process the User’s payment data in accordance with their own terms, policies and security requirements.
7.4. The Operator receives from the Payment Aggregator only the information necessary to confirm the payment, credit funds, perform the Order, issue a refund, conduct an anti-fraud check, resolve a dispute or chargeback and maintain accounting and legal records.
7.5. The Operator may provide payment partners with information about the Order, account, amount and purpose of the payment, technical parameters, IP address, device and other information where necessary to process a payment or refund, conduct an anti-fraud check, comply with payment system requirements or prevent abuse.
7.6. The Operator shall not be responsible for the actions of a Payment Aggregator, bank or payment system, including refusal to process a payment, placing a hold, blocking a transaction, currency conversion, charging fees, conducting an anti-fraud check, applying sanctions-related restrictions or taking other actions as a payment intermediary.
8. Disclosure of Data to Third Parties
8.1. The Operator does not sell Users’ personal data to third parties.
8.2. The Operator may disclose data to third parties to the extent necessary for the operation of the Service and achievement of the processing purposes, including:
- partners and contractors engaged to perform Orders, limited to the technical Order data necessary for performance, including the link, type of Service, quantity, parameters, status, comments and other necessary information;
- Payment Aggregators, banks, payment systems, anti-fraud services and processing centres;
- hosting providers, server infrastructure providers, content delivery networks, backup services and technical support and security providers;
- analytics services, customer relationship management systems, ticket systems, email services and other technical providers used by the Service;
- public authorities, courts, law enforcement agencies, tax authorities and other authorised persons where required by applicable law;
- consultants, lawyers, accountants and other persons where necessary to protect rights, comply with legal requirements or maintain records.
8.3. The Operator seeks to disclose to third parties only the minimum amount of information necessary for the relevant processing purpose.
8.4. The User understands that social media platforms, Payment Aggregators, banks, hosting providers and other external services are not owned by Votway and may apply their own data processing rules.
9. Cross-Border Data Transfers
9.1. When the Service is used, data may be transferred to and processed in foreign countries where necessary for hosting, analytics, payments, anti-fraud checks, performance of Orders, technical support, operation of contractors or other Service functions.
9.2. By using the Service, the User understands that partners, contractors, Payment Aggregators, social media platforms and technical providers may be located in different jurisdictions and may process data in accordance with their own rules and applicable laws.
9.3. The Operator takes reasonable measures to ensure that such transfers are limited to the extent necessary for the processing purposes and operation of the Service.
10. Data Retention Periods
10.1. Data shall be retained no longer than necessary for the purposes of processing, operation of the Service, performance of the Terms of Service, fulfilment of Orders, processing of payments and refunds, resolution of disputes, compliance with legal requirements and protection of the Operator’s rights.
10.2. Account information and Order history may be retained throughout the period in which the Service is used and after the User stops using the Service to the extent necessary to confirm that Services were provided, maintain accounting records, defend against claims, process refunds and chargebacks and comply with legal requirements.
10.3. Support correspondence, tickets, technical logs and information relating to payments, refunds, disputed transactions and anti-fraud checks may be retained for the period necessary to review a request, resolve a dispute, confirm provision of the Service and protect the Operator’s rights.
10.4. Once the purposes of processing have been achieved, data shall be deleted, anonymised or archived unless further retention is required by law, payment rules, accounting requirements or the need to protect the Operator’s rights.
11. Data Protection
11.1. The Operator takes reasonable organisational and technical measures to protect data against unauthorised access, alteration, disclosure, deletion, copying, loss and other unlawful actions.
11.2. Such measures may include access restrictions, passwords and technical security tools, activity logging, backups, allocation of access rights, anti-fraud checks and other measures appropriate to the nature of the Service.
11.3. The User is responsible for keeping their username, password, email address, access codes and other authentication credentials secure. The Operator shall not be responsible for actions of third parties who obtained access to the User’s account as a result of the User’s actions or omissions.
11.4. Transmission of data over the internet cannot be completely secure. The Operator does not guarantee absolute protection against every possible threat but takes reasonable measures to reduce the relevant risks.
12. User Rights
12.1. The User may contact the Operator regarding the processing of their data using the email address specified in Section 15 of this Policy.
12.2. To the extent provided by applicable law, the User may request:
- confirmation that personal data is being processed;
- information about the purposes, categories, sources, retention periods and methods of data processing;
- correction, amendment or updating of data;
- deletion of data where it is no longer required for the processing purposes and its retention is not required by law, an agreement, payment rules, protection of the Operator’s rights or resolution of a dispute;
- restriction of processing in the cases provided by applicable law;
- withdrawal of consent where processing is based on consent.
12.3. To protect the User’s data, the Operator may request information necessary to identify the relevant account, Order or request. Where the User cannot be reliably identified, the Operator may refuse to provide information or take the requested action until the User’s identity or lawful ownership of the account has been confirmed.
12.4. Deletion of data or restriction of its processing may make it impossible to use the account, perform Orders, process payments or refunds, handle requests or provide other Service functions.
12.5. The Operator shall review requests within a reasonable period unless another period is established by applicable law, the rules of a payment system or Payment Aggregator or the requirements of an authorised authority.
13. Children and Minors
13.1. The Service is intended for persons who have reached the age of full legal capacity under applicable law, unless otherwise expressly permitted by law and the Terms of Service.
13.2. If the Operator becomes aware that data has been provided by a minor without the required consent of a legal representative, the Operator may restrict access to the account, delete the data or request additional information for verification.
14. Amendments to the Policy
14.1. The Operator may amend this Policy. A new version shall take effect from the moment it is published on the Website unless another effective date is specified in that version.
14.2. Continued use of the Website following publication of a new version of the Policy means that the User has read and understood the amendments.
14.3. The current version of the Policy shall be published on the Website and made available to the User at any time.
15. Operator Information and Contact Details
15.1. The Operator under this Policy is:
- Operator
- an individual payer of professional income tax carrying out independent professional activities in accordance with the procedure established by the laws of the Republic of Belarus
- Contact email
- votway@mail.ru
- Website
- votway.com
15.2. User requests concerning personal data processing, operation of the Service, Orders, payments, refunds, claims and other matters shall be submitted to the specified email address or through the support service available on the Website.
15.3. The Operator’s passport details, bank card details, personal documents, bank account numbers and other information not required to be publicly disclosed shall not be published on the Website.
15.4. Additional information may be provided to Payment Aggregators, banks, public authorities and other authorised persons in the cases and in accordance with the procedure established by applicable law, payment system rules and this Policy.
16. Final Provisions
16.1. If any provision of this Policy is held to be invalid or unenforceable, this shall not affect the validity of the remaining provisions.
16.2. This Policy shall remain in effect indefinitely until replaced by a new version.
16.3. The current version of this Policy is published on votway.com and applies to all Users of the Service.