Privacy Policy
1. This Privacy Policy (hereinafter referred to as the “Policy”) applies to all information, including personal data as defined by applicable legislation (hereinafter referred to as “Personal Information”), that Anykod may obtain about you during your use of any of Anykod’s websites, programs, products, and/or services (collectively, the “Services”), information about which can be found on the website Anykod.com (hereinafter referred to as the “Website”) and other websites owned by Anykod (collectively, the “Websites”), as well as during the performance of any agreements or contracts concluded with you in connection with your use of the Services.
2. General Provisions
2.1. Anykod may also obtain Personal Information from its partners (hereinafter referred to as “Partners”), whose websites, programs, products, or services you use (e.g., Anykod’s advertisers). In such cases, the transfer of Personal Information is only possible in situations permitted by applicable legislation and is carried out based on specific agreements between Anykod and each Partner.
2.2. Please note that the use of any of the Websites and/or Services may be subject to additional terms, which may amend and/or supplement this Policy and/or include specific conditions regarding Personal Information, as outlined in the relevant sections of documents for such Websites and/or Services. Please review our Cookie Policy.
2.3. When processing personal data, Anykod adheres to the standards of international law and the legislation of the EU, Russia, and Ukraine. In particular, this Policy complies with the standards of Federal Law No. 152-FZ of July 27, 2006 (as amended on July 2, 2021) “On Personal Data” and the Ukrainian Law “On Personal Data Protection.”
2.4. In case of significant changes to the Policy, we will notify you accordingly. Anykod may also request your consent to continue processing personal data, even if you have previously provided such consent.
2.5. Anykod welcomes your questions and suggestions regarding the implementation or amendment of this Policy. Please use our feedback form located at: https://anykod.freshdesk.com/support/tickets/new. You may also use this form (or the email address info@anykod.com) to submit requests regarding the exercise of your rights or complaints about the inaccuracy of your Personal Information or the unlawfulness of its processing.
3. Purpose of this Policy
3.1. Protecting your Personal Information and privacy is extremely important to Anykod. When you use the Websites and Services, Anykod protects and processes your Personal Information in strict compliance with applicable legislation. To fulfill our obligations to protect your Personal Information, this Policy aims to transparently inform you about the following:
3.2. Transactional Information and Orders
3.2.1. Any personal data you provide to us and/or other users of our Website when placing an order, responding to a message, accepting order terms, discussing transaction details, and/or performing other actions related to trading services and Services on our Website. Examples of data we may collect include, but are not limited to: account details, information required to access your personal account, and email address.
3.3. Registration and Use of Forms
3.3.1. Personal Information provided by you during registration (account creation), form submissions (e.g., feedback form), or when contacting support. For example: your name, IP address, email address, and cookies.
3.4. Data and Content Stored in Anykod’s Systems
3.4.1. Information about your activity while using the Websites and/or Services. For example, purchase data within the Services, usage data of the Services themselves, information about interactions with other users, as well as files and content stored in Anykod’s systems, including your reviews on third-party websites and/or resources, comments about the quality of our Services and/or Website, and any data necessary for the successful resolution of complaints and the operation of our arbitration service.
3.5. Dispute Resolution
3.5.1. The successful resolution of complaints and the proper functioning of our arbitration service are crucial to us and our ability to provide you with our services. Therefore, we may require certain personal data to fully address your complaints or complaints concerning you. Anykod reserves the right to publish and/or use certain types of personal data necessary to protect its business reputation and brand reputation.
3.6. Technical Data and Analytics
3.6.1. For detailed analysis and collection of technical data, Anykod uses a set of features (including cookies) that may collect your personal data. Anykod also uses third-party web analytics tools to collect information about traffic sources, website visits, and the effectiveness of our Services. For example, we use: Yandex.Metrika and Google Analytics. Types of personal data collected this way include: date and time of access to the Websites and/or Services, electronic data (HTTP headers, IP address, cookies, browser identifier, and software data).
3.6.2. For more details on how we use Yandex.Metrika and Google Analytics, refer to section 4.1 of this Policy, as well as sections 4.2.2 and 4.2.3 of our Cookie Policy.
3.7. Sensitive Personal Data
3.7.1. Anykod does not intentionally collect sensitive personal information (such as racial or ethnic origins, political opinions, health information, or biometric data), except in cases permitted by law.
4. Who Else Has Access to Your Personal Information and to Whom It May Be Transferred
4.1. Anykod may transfer your Personal Information to its employees (within the limits of applicable legislation). Anykod may also transfer your Personal Information to its affiliates, including third parties and services with which Anykod collaborates. Please note that the level of Personal Information protection in some countries may not match the level established in your jurisdiction, and by using our Services and/or Website, you consent to such transfers. These third parties include: Yandex.Metrika, Google Analytics, Freshdesk, and payment system operators.
4.2. Anykod may receive certain data from third parties that may be required under law or to fulfill contractual obligations, such as your payment details (e.g., masked payment card information).
4.3. When processing data obtained as described in section 4.1, Anykod complies with international law and the legislation of the EU, Russia, and Ukraine.
5. Legal Basis and Purposes of Processing Your Personal Information
5.1. In addition to section 3 of this Policy, Anykod processes your Personal Information only if:
5.1.1. It is necessary to provide access to your account, including personal account settings and other tools on our Website.
5.1.2. Processing is necessary to fulfill Anykod’s contractual obligations to you, including ensuring the operation of the Websites and Services.
5.1.3. Processing is necessary to comply with legal obligations.
5.1.4. Processing is necessary to improve the quality of our services and/or to understand how you interact with our Websites and/or Services.
5.1.5. When permitted by applicable legislation, processing is necessary to pursue Anykod’s legitimate interests, provided such processing does not significantly impact or harm your interests, rights, or freedoms.
5.2. For specific purposes or in accordance with applicable legislation, we may request your separate consent to process your Personal Information. In jurisdictions where consent is recognized as a separate legal basis, your use of Anykod’s Websites and/or Services constitutes your consent to such processing. We hereby inform you, and you confirm, that you have no obligation to provide us with any Personal Information when using the Websites or Services, and such provision is based solely on your free will. However, you acknowledge that without providing Personal Information, we may not be able to provide you with access to the Services, and your use of the Websites may be limited.
5.3. Anykod always processes your Personal Information for the purposes outlined in section 5 and only processes Personal Information relevant to achieving those purposes.
5.4. Anykod may sometimes use technical solutions, tools, and services from third parties (e.g., services of our payment partners). These solutions, tools, and services may process your data for purposes different from those listed in section 5 of this Policy. Anykod is not responsible for the data processing practices of third parties. Nevertheless, we welcome your questions and suggestions regarding the processing of your data by third parties. Please use our feedback form at: https://anykod.freshdesk.com/support/tickets/new to contact us.
6. How We Use Cookies
6.1. Cookies are small pieces of data containing specific (often technical) information that a server sends to your device to store information about your preferences. This information is used by the Website to analyze your actions and display the Website in a format convenient for you. For example, the “locale” cookie allows our Website and other Services to display information in the language you typically use (or have manually selected).
6.2. Anykod uses session cookies to provide a more convenient experience with our Services. For example, cookies such as PHPSESSID and golden_key store your choices during authorization in the Services or when completing CAPTCHA tests. Session cookies expire at the end of a session (when you close the page or browser window). For more details on storage periods and examples of cookie usage, refer to sections 3.3 and 4.1.3 of our Cookie Policy.
7. Where Your Personal Information Is Stored and Processed
7.1. Your Personal Information will be stored in the Russian Federation and/or the EEA.
7.2. For users from Russia and Belarus: Anykod records, systematizes, accumulates, stores, updates, and extracts personal data of Russian Federation citizens using databases located in the Russian Federation.
7.3. For users from the EEA: Anykod records, systematizes, accumulates, stores, updates, and extracts personal data of EEA citizens using databases located in the EEA.
7.4. If you are located in a jurisdiction where your consent is required for the transfer of your Personal Information to another jurisdiction, by using the Websites or Services, you provide Anykod with your explicit and unambiguous consent to such transfer, storage, and/or processing of information in other specified jurisdictions, including Russia.
7.5. Anykod also implements appropriate measures to ensure that such transfers comply with applicable EU and Russian data protection regulations (for the transfer of Russian citizens’ data). Anykod also uses Standard Contractual Clauses that permit the transfer of your Personal Information to Russia.
8. How Long We Store Your Personal Information
8.1. Anykod retains your data for the period necessary to achieve the purpose for which it was collected or to comply with legal and regulatory requirements.
8.2. If you wish for any of your Personal Information to be deleted, you may submit a corresponding request to us.
8.3. After the retention period expires, your data is deleted or anonymized.
8.4. If your data was collected and processed based on your consent, we will delete your data without affecting other legal relationships if you withdraw your consent. Your withdrawal will not affect your legal status but may limit the functionality available to you on our Website and/or Services.
9. Your Rights
9.1. If provided for by applicable legislation, you have the right to access your Personal Information processed by Anykod under this Policy.
9.2. If you believe that any information Anykod holds about you is inaccurate or incomplete, you have the right to request that we supplement or correct your information.
9.3. You also have the right to review the information Anykod holds about you.
9.4. You may request the deletion of your Personal Information or parts thereof and withdraw your consent to the processing of your Personal Information.
9.5. You may request restrictions on the processing of your Personal Information.
9.6. You may request a copy of the Standard Contractual Clauses permitting the transfer of your Personal Information to Russia, as mentioned in section 7.5 of this Policy.
9.7. You may object to the processing of your Personal Information if permitted by applicable legislation.
9.8. In cases provided for by applicable legislation, you may also have other rights not listed above.
9.9. When using the Services, the transfer of Personal Information is carried out with your consent, expressing your free will and interest (in particular, based on a contract with you), and is not a legal obligation.
10. Feedback
10.1. Anykod welcomes your questions and suggestions regarding the implementation or amendment of this Policy. Please use our feedback form located at: https://anykod.freshdesk.com/support/tickets/new. You may also use this form (or the email address info@anykod.com) to submit requests regarding the exercise of your rights or complaints about the inaccuracy of your Personal Information or the unlawfulness of its processing.