1. Definition of terms
1.1 The following terms are used in this Privacy Policy:
1.1.1. «Website Administration» (hereinafter referred to as the Administration) – authorized employees for the management of the Bora website who organize and (or) process personal data, as well as determine the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
1.1.2. «Personal data» means any information related directly or indirectly to a certain or identifiable individual (the subject of personal data).
1.1.3. «Personal data processing» means any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
1.1.4. «Confidentiality of personal data» is a mandatory requirement for the Operator or other person who has access to personal data to prevent their dissemination without the consent of the personal data subject or the presence of other legal grounds.
1.1.5. The «Bora Website» is a set of interconnected web pages located on the Internet at a unique address (URL):, as well as its subdomains.
1.1.6. «Subdomains» are pages or a set of pages located on third-level domains belonging to the Bora website, as well as other temporary pages, at the bottom of which the contact information of the Administration is indicated
1.1.5. «User of the Bora website» (hereinafter referred to as the User) is a person who has access to the Bora website via the Internet and uses the information, materials and products of the Bora website.
1.1.7. «Cookies» — a small piece of data sent by the web server and stored on the user’s computer, which the web client or web browser sends to the web server each time in an HTTP request when trying to open the page of the corresponding site.
1.1.8. «IP address» is a unique network address of a node in a computer network through which the User gets access to Bora.

2. General provisions
2.1. The use of the Bora website by the User means acceptance of this Privacy Policy and the terms of processing of the User’s personal data.
2.2. In case of disagreement with the terms of the Privacy Policy, the User must stop using the Bora website.
2.3. This Privacy Policy applies to the Bora website. Bora does not control and is not responsible for the third-party sites to which the User can click on the links available on the Bora website.
2.4. The Administration does not verify the accuracy of the personal data provided by the User.


3. Subject of the Privacy Policy
3.1. This Privacy Policy establishes the obligations of the Administration for non-disclosure and ensuring the confidentiality of personal data that the User provides at the request of the Administration when registering on the Bora website or when subscribing to an e-mail newsletter.
3.2. The personal data allowed for processing under this Privacy Policy is provided by the User by filling out forms on the Bora website and includes the following information:
3.2.1. the User’s last name, first name, patronymic;
3.2.2. The User’s contact phone number;
3.2.3. e-mail address (e-mail)
3.2.4. the User’s place of residence (if necessary)
3.2.5. photo (if necessary)
3.3. Bora protects the Data that is automatically transmitted when visiting the pages:
— IP address;
— information from cookies;
— information about the browser
— access time;
— referrer (the address of the previous page).
3.3.1. Disabling cookies may result in the inability to access parts of the site that require authorization.
3.3.2. Bora collects statistics about the IP addresses of its visitors. This information is used for the purpose of preventing, detecting and solving technical problems.
3.4. Any other personal information not mentioned above (browsing history, browsers used, operating systems, etc.) is subject to reliable storage and non-proliferation, except for the cases provided for in clause 5.2. of this Privacy Policy.

4. Purposes of collecting the user’s personal information
4.1. The Administration may use the User’s personal data for the following purposes:
4.1.1. Identification of the User registered on the Bora website for his further authorization.
4.1.2. Providing the User with access to the personalized data of the Bora website.
4.1.3. Establishing feedback with the User, including sending notifications, requests regarding the use of the Bora website, processing requests and requests from the User.
4.1.4. Determining the User’s location to ensure security and prevent fraud.
4.1.5. Confirmation of the accuracy and completeness of the personal data provided by the User.
4.1.6. Creating an account for using parts of the Bora website, if the User has agreed to create an account.
4.1.7. User notifications by e-mail.
4.1.8. Providing the User with effective technical support in case of problems related to the use of the Bora website.
4.1.9. Providing the User with his consent with special offers, newsletters and other information on behalf of the Bora website.

5. Methods and terms of processing personal information
5.1. The processing of the User’s personal data is carried out without a time limit, in any legal way, including in personal data information systems using automation tools or without using such tools.
5.2. The User’s personal data may be transferred to the authorized state authorities of Republic of Estonia only on the grounds and in accordance with the procedure established by the legislation of Republic of Estonia.
5.3. In case of loss or disclosure of personal data, the Administration has the right not to inform the User about the loss or disclosure of personal data.
5.4. The Administration takes the necessary organizational and technical measures to protect the User’s personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.
5.5. The Administration, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data.

6. Rights and obligations of the parties
6.1. The User has the right to:
6.1.1. Make a free decision on the provision of their personal data necessary for the use of the Bora website, and consent to their processing.
6.1.2. Update, supplement the provided information about personal data in the event of a change in this information.
6.1.3. The User has the right to receive information from the Administration regarding the processing of his personal data, if such a right is not restricted in accordance with federal laws. The User has the right to demand from the Administration to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect his rights. To do this, it is enough to notify the Administration at the specified E-mail address.
6.2. The Administration is obliged to:
6.2.1. Use the received information exclusively for the purposes specified in clause 4 of this Privacy Policy.
6.2.2. To ensure that confidential information is kept secret, not to disclose it without the User’s prior written permission, as well as not to sell, exchange, publish, or disclose the User’s personal data transmitted in other possible ways, except for clause 5.2. of this Privacy Policy.
6.2.3. Take precautions to protect the confidentiality of the User’s personal data in accordance with the procedure usually used to protect such information in the existing business turnover.
6.2.4. To block personal data related to the relevant User from the moment of the User’s request or request, or his legal representative or the authorized body for the protection of the rights of personal data subjects for the period of verification, in case of identification of false personal data or illegal actions.

Responsibility of the parties
7.1. The Administration, which has not fulfilled its obligations, is liable for losses incurred by the User in connection with the illegal use of personal data, in accordance with the legislation of Republic of Estonia, except for the cases provided for in paragraphs 5.2. and 7.2. of this Privacy Policy.
7.2. In case of loss or disclosure of Confidential Information, the Administration is not responsible if this confidential information:
7.2.1. Became public domain before its loss or disclosure.
7.2.2. It was received from a third party before it was received by the Resource Administration.
7.2.3. It was disclosed with the consent of the User.

1. Terms
By accessing the website at http://bora.systems, your area greeting to be bound by these terms of service, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this website are protected by applicable copyright and trademark law.

2. Use License
Permission is granted to temporarily download one copy of the materials (information or software) on Bora Systems website for personal, non-commercial transitory viewing only. This is the grant of a license, not a transfer of title, and under this license you may not:

• modify or copy the materials;
• use the materials for any commercial purpose, or for any public display (commercial or non- commercial);
• attempt to decompile or reverse engineer any software contained on Bora Systems website; remove any copyright or other proprietary notations from the materials; or transfer the materials to another person or “mirror" the materials on any other server.

This license shall automatically terminate if you violate any of these restrictions and may be terminated by Bora Systems at any time. Upon terminating your viewing of these materials or upon the termination of this license, you must destroy any downloaded materials in your possession whether in electronic or printed format.

3. Disclaimer
The materials on Bora Systems website are provided on an ‘as is' basis. Bora Systems makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties including, without limitation, implied warranties or conditions of merchant ability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights.
Further, Bora Systems does not warrant or make any representations concerning the accuracy, likely results, or reliability of these of the materials on its website or otherwise relating to such materials or on any sites linked to this site.

4. Limitations
In no event shall Bora Systems or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption) arising out of the use or inability to use the materials on Bora Systems website, even if Bora Systems authorized representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you.

5. Accuracy of materials
The materials appearing on Bora Systems website could include technical, typographical, or photographic errors. Bora Systems does not warrant that any of the materials on its website are accurate, complete or current. Bora Systems may make changes to the materials contained on its website at any time without notice. However, Bora Systems does not make any commitment to update the materials.

6. Links
Bora Systems has not reviewed all of the sites linked to its website and is not responsible for the contents of any such linked site. The inclusion of any link does not imply end or segment by Bora Systems of the site. Use of any such linked website is at the user's own risk.

7. Modifications
Bora Systems may revise these terms of service for its website at any time without notice. By using this website you are agreeing to be bound by the then current version of these terms of service.

8. Governing Law
These terms and conditions are governed by and construed in accordance with the laws of Republic of Estonia.

This Data Processing and Protection Policy (hereinafter referred to as the Policy) has been accepted and considered effective for Bora Systems, 12618, Republic of Estonia, Tallinn, Academia tee 15a, (hereinafter the Company).
We collect, use, and store Personal Data, which you provide while using our site and mobile application (hereinafter the site) or communicate to us in any format, in accordance with this Policy.
By using our sites and providing your Personal Data, you consent to having your Personal Data processed in accordance with this Policy.

Key Concepts
Personal Data is any information pertaining directly or indirectly to any identified or identifiable individual.
Personal Data processing is any action or combination of actions pertaining to your Personal Data, including collecting, recording, systematizing, storing, updating and modifying, extracting, using, transferring (distributing, providing, accessing), anonymizing, blocking, and deleting and destroying, performed both with and without an automated data processing system.

Data we gather
We gather:

• Personal Data that you provide by filling in information fields on our site, including contact forms, signing up for news and updates, registering for events, and registering to conclude a contract as well as accepting offers;
• Personal Data and other information contained in messages addressed to us;
• Personal Data which you provide by responding to our vacancies;
• technical data which is automatically transferred by the device you use
• to access our site, including the technical specifications of your device,
• IP address, information sent to your device and stored in cookies, browser information, the date and time our site was accessed, the addresses
• of requested pages, and any other similar information;
• other personal information which you willingly submit on our site.

Purpose of Processing Data
We process your Personal Data exclusively to achieve the purposes they were provided for, including:

• registering you on our website and granting you access to its individual sections, including creating an account and rendering services within the framework of the contract;
• providing information about the Company, our services, and events;
• communicating with you and when you contact us;
• making arrangements for your participation in our events and surveys;
• sending Company news and updates;
• exercising authority and performing all obligations imposed upon the company by law of Republic of Estonia;
• all other purposes you consent to.

We process technical data:

• to ensure the functionality and security of our sites;
• to improve the quality of our site.

We do not host your Personal Data on any public data sources. We do not make any decisions which would carry legal consequences or in any way affect your rights and legal interests based on exclusively automated data processing.

Your Rights
The protection of your rights and freedoms in the field of Personal Data is of the utmost importance to the Company.
To protect your rights and freedoms, we will at your request:

• confirm that we process your Personal Data and provide you the opportunity to review it within 30 days of receiving your request;
• inform you of the source and contents of your Personal Data which we process;
• inform you of the legal grounds, purposes, terms, and methods in which your Personal Data is processed;
• make all necessary changes to your Personal Data provided you verify that such data is incomplete, inaccurate, or irrelevant within 7 days of receiving your verification and notify you of the changes made;
• inform you of any intended or completed cross-border transfers of your Personal Data;
• provide you the name and address of any organization that has access to your Personal Data and that may disclose your Personal Data with your consent;
• notify you of the full name and address of any entity which may be entrusted to process your Personal Data with your consent;
• inform you of how to exercise your rights when we process your Personal Data;
• exclude you from our newsletter and other news and update mailing lists;
• cease processing your Personal Data within 30 days of receiving a withdrawal of consent unless there exist any legal grounds provided under Republic of Estonia law for processing your Personal Data;
• cease processing your Personal Data, provided it is verified that it is processed illegally and notify you of the measures taken;
• destroy your Personal Data, provided it is verified that it was unlawfully obtained or does not correspond to the declared purpose for processing, within 7 business days of receiving relevant verification and notify you of the measures taken; and
• answer questions related to your Personal Data that we process.

Contacting Us
Please send all of your enquiries pertaining to the processing of your Personal Data in a letter with the subject line “Personal Data Enquiry” (or “Withdrawal of Consent to Data Processing”) via e-mail to info@bora.systems or by post to 12618,Republic of Estonia, Tallinn, Academia tee 15a.

Personal Data Protection
To protect your Personal Data during processing, we take all appropriate, legal, organizational, and technical measures necessary to protect Personal Data from unlawful and incidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions pertaining to Personal Data.
With the goal of adequately safeguarding your Personal Data, we evaluate all damage which could be caused by a violation of the security of your Personal Data, as well as determine current threats to the security of your Personal Data while being processed in Personal Data information systems.
Local acts have been accepted by the Company regarding questions of Personal Data protection. Company employees with access to Personal Data have been familiarized with this Policy and local acts pertaining to Personal Data protection.

Cross-Border Data Transfers
We transfer your Personal Data to foreign countries. Ensuring your Personal Data is secure during transfers is of the utmost importance to us. We take all necessary measures to ensure the confidentiality and security of your Personal Data.
Cross-border transfers of Personal Data to foreign countries that do not adequately protect Personal Data shall only be made with your written consent, to fulfill
a contract to which you are party, or in other situations provided for under Estonian legislation pertaining to Personal Data.

Suspending Data Processing
We will cease to process your Personal Data:

• if conditions dictate data processing be suspended or the established timeframe expires;
• if the purpose for which data is processed is achieved or in the event of frustration of purpose to achieve these purposes;
• upon your request, provided the Personal Data to be processed has been unlawfully obtained or is deemed unnecessary for achieving the declared purpose for processing;
• in the event it is made known that your Personal Data is unlawfully processed and data processing cannot be legally justified;
• upon the expiration of the effective term of your consent to the processing of Personal Data or upon receipt of your withdrawal of consent, unless there exist any legal grounds provided under Republic of Estonia law for processing your Personal Data; or if the Company is liquidated.

Cookies
We use cookies. Cookies are small text files that are stored on your device’s hard disk while visiting various websites. The purpose of these files is to facilitate the configuration of the user interface to your preferences.
Most browsers allow you to disable cookies and clear them from your device’s hard disk.

Links to Third-Party Sites
Our sites contain links to external sites and services, which are beyond our control. We are not liable for the security or confidentiality of any information collected by external sites or services.

Policy Changes
We may update this Policy to whatever extent necessary. We recommend you periodically check the relevance of this Policy. By continuing to use our site after any changes are made to the Policy, you agree to all changes made.
If you have any questions regarding this Policy, you may contact the Company point of contact for all data processing by sending a letter with the subject “Personal Data Enquiry” by e-mail to info@bora.systems or by post to 12618, Republic of Estonia, Tallinn, Academia tee 15a.