Privacy Policy
Please read this Privacy policy carefully. It explains the types of information we may collect about you, the purposes for and methods by which we collect it, and (where applicable) the lawful basis on which we do so, as well as information about data retention, your rights and how to contact us.
The current Privacy Policy for personal data (hereinafter referred to as the „Privacy Policy”) applies to all information that the website howtomove.help (hereinafter referred to as “Howtomove website”) , located at the domain name howtomove.help (as well as its subdomains), may collect about you as the user during the use of the Howtomove website (as well as its subdomains), its softwares, its services and its products (including but not limited to telegram bots).
This Privacy Policy covers both our online and offline data processing activities as set out below:
1. Definitions
1.1. In this Privacy Policy, the following terms are used:
1.1.1. "Website Administration" (hereinafter referred to as the Administration) – authorized personnel responsible for managing the Howtomove website, who organize and/or carry out the processing of Personal Data and determine the purposes of processing Personal Data, the composition of Personal Data Subject to processing, actions (operations) performed with Personal Data, including the person legally appointed as responsible for lawful processing of Personal Data on behalf of our Company (hereinafter „Data Protection Officer“).
1.1.2. "Personal Data" - any information related directly or indirectly to an identified or identifiable individual (Personal Data Subject).
1.1.3. "Personal Data Processing" - any action (operation) or a set of actions (operations) performed with Personal Data, using automation tools or without the use of such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transmission (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal Data.
1.1.4. "Confidentiality of Personal Data" - a requirement that the operator or any other person who has access to Personal Data must comply with, which prohibits the dissemination of Personal Data without the consent of the Personal Data Subject or the presence of another legal basis.
1.1.5. "Howtomove website" - a collection of interconnected web pages located on the internet at a unique address (URL): howtomove.help, as well as its subdomains, its softwares, its services and its products.
1.1.6. "User of the Howtomove website (as well as its subdomains), its softwares, its services and its products" (hereinafter referred to as the „User”) – an individual who has access to the Howtomove website via the internet and uses the information, materials, and products of the Howtomove website.
1.1.7. "Cookies" – small pieces of data sent by a web server and stored on a User's computer, which the web client or web browser sends back to the web server in an HTTP request each time an attempt is made to open a page of the corresponding website.
1.1.8. "IP Address" – a unique network address of a node in a computer network through which the User accesses Howtomove website.
2. General Provisions
2.1. The use of the Howtomove website by the User signifies their agreement with this Privacy Policy and the terms of processing the User's Personal Data.
2.2. In case of disagreement with the terms of the Privacy Policy, the User must discontinue the use of the Howtomove website.
2.3. This Privacy Policy applies to Howtomove website. Howtomove website does not control and is not responsible for third-party websites that the User may access through links available on the Howtomove 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 Administration's obligations regarding the non-disclosure and ensuring the confidentiality of Personal Data that the User provides at the request of the Administration when registering on Howtomove website or subscribing to informational email newsletters.
3.2. The Personal Data permitted for processing under this Privacy Policy is provided by the User by filling out forms on the Howtomove website or otherwise accessing Howtomove website and includes the following information:
3.2.1. The User's last name, first name, and patronymic (if applicable).
3.2.2. The User's contact phone number.
3.2.3. The User's email address.
3.2.4. The User's place of residence (if necessary).
3.2.5. A photograph (if necessary).
3.2.6. Username and password
3.2.7. Geolocation information
3.2.8. Device information, such as when you accessed our services and information about the device used (for example, IP address, software or internet browser used, preferred languages)
3.2.9. Online activity, including pages you have visited and content reviewed
3.2.10. Other information about you that you have voluntarily disclosed
3.3. Disabling cookies may result in the inability to access certain parts of the Howtomove website that require authentication.
3.4. Howtomove website collects statistics on the IP addresses of its visitors. This information is used to prevent, detect, and resolve technical issues.
3.5. Any other Personal Data not mentioned above (browsing history, used browsers, operating systems, etc.) is subject to secure storage and non-disclosure, except as provided in clause 5.2. of this Privacy Policy.
4. Purposes of Collecting User's Personal Data
4.1. The Administration may use the User's Personal Data for the following purposes:
4.1.1. Identifying the User registered on the Howtomove website for their subsequent authorization.
4.1.2. Providing the User with access to Personal Data on the Howtomove website.
4.1.3. Establishing feedback with the User, including sending notifications, inquiries regarding the use of the Howtomove website, processing requests, and applications from the User.
4.1.4. Determining the User's location to ensure security and prevent fraud.
4.1.5. Confirming the accuracy and completeness of the Personal Data provided by the User.
4.1.6. Creating a User account for using parts of the Howtomove website if the User has consented to the creation of an account.
4.1.7. Notifying the User via email.
4.1.8. Providing the User with effective technical support in case of issues related to the use of the Howtomove website.
4.1.9. Use your information for analytical purposes and to enable us to improve our services.
4.1.10. Host your comments, forum posts, photos, videos, and other content.
4.1.11. Respond to your questions and comments.
4.1.12. Providing the User with special offers, newsletters, and other information on behalf of the Howtomove website with the User's consent.
5. Methods and Terms of Processing Personal Data
5.1. The processing of the User's Personal Data is carried out without a time limit, by any lawful method, 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 authorized state authorities of Montenegro only on the grounds and in the manner established by the legislation of Montenegro.
5.3. In the event 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 necessary organizational and technical measures to protect the User's Personal Data from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions by third parties. The Administration and the Company won’t be liable for any damages and/or loss which might occur to User/s and or third parties in case of User’s Personal Data unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions by third parties if such unlawful actions are not direct consequence of Company’s/Administration’s gross negligence or willful misconduct.
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.
5.6. Our affiliates, partners and contractors have access to Personal Data only to the extent necessary to help carry out the services they are performing for us, such as, but not limited to, fulfilment, creation, maintenance, hosting, and delivery of our services, conducting marketing, providing IT services and security, handling payments, email and order fulfillment, administering promotions, conducting research, measurement and analytics, deriving insights, or customer service/technical support.
5.7. Some of our services contain links to other sites, for the purposes of customer interaction and marketing. The information practices of such other sites can be different from ours so you should consult their privacy policy and terms before submitting your Personal Data, as we have no control over Personal Data that is submitted to or collected by these third parties.
5.8. If you post or share Personal Data while interacting through interactive areas available on Howtomove webiste, depending on the nature and publicity of the interaction this Personal Data can become public, after which, we cannot prevent further use or sharing of this Personal Data
5.9. Data retention. In broad terms, we will only retain your Personal Data for as long as is necessary for the purposes described in this Privacy Policy. This means that the retention periods will vary according to the type of Personal Data and the reason that we have collected the Personal Data in the first place. For example, some Personal Data related to the provision of our services to you will be kept for a number of years in order to comply with various finance and tax related legal obligations. After a retention period has lapsed, the Personal Data is securely deleted unless it is necessary for the establishment, exercise, or defense of legal claims. For further information regarding applicable retention periods, you should contact us using the contact methods set out in clause 6.3 below.
6. Rights and Obligations of the Parties
6.1. The User has the right to:
6.1.1. Make a free decision on providing their Personal Data necessary for using the Howtomove website, and give consent to their processing.
6.1.2. Update or supplement the provided Personal Data information in case of changes in this Personal Data.
6.2. Under certain conditions, the User has the following rights:
6.2.1. You can request details of the Personal Data we hold, along with a copy of your Personal Data, unless this right is restricted in accordance with applicable law.
6.2.2. Right to erasure (“right to be forgotten”): The right, in certain circumstances, to ask for your Personal Data to be deleted. In specific cases, we may not be able to delete some types of Personal Data, in particular, where we have a legal obligation to keep that Personal Data (e.g. for regulatory reporting purposes) or, for example, where you want us to continue to provide you with services and the processing of the Personal Data is necessary for the provision of those services.
6.2.3. Right to object: The right to object (on grounds relating to your particular situation) to the processing of your Personal Data on the basis of your legitimate interests.
6.2.4. Right to withdraw consent: You can withdraw your consent at any time in respect of any processing of Personal Data which is based upon a consent.
6.3. We will assess any request to exercise these rights on a case by case basis. There may be circumstances in which we are not legally required to comply with a request because of relevant exemptions provided for in applicable data protection legislation. In some instances, this may mean that we are able to retain your Personal Data even if you withdraw your consent. To exercise these rights, or to contact our Data Protection Officer, please direct your request to:
Falicon DOO Budva, Montenegro
Andrei Raskovalkin, CEO
falicon@proton.me
6.4. The Administration is obliged to:
6.4.1. Use the received Personal Data exclusively for the purposes specified in clause 4 of this Privacy Policy.
6.4.2. Take precautions to protect the confidentiality of the User's Personal Data according to the procedure normally used for protecting such data in existing business transactions.
6.4.3. Block and/or erase (as appropriate) Personal Data related to the respective User from the moment of the User's or their legal representative's request, or the request of an authorized body for the protection of Personal Data subjects' rights, for the period of verification, in case of detection of unreliable personal data or unlawful actions.
7. Cookies
7.1. When you visit our Howtomove website, we and/or third party service providers, and/or our partners may use "cookies" or similar technologies, such as pixels and SDKs to (i) provide, develop, maintain, personalize, protect, and improve our services and their content (ii) perform analytics, including to analyse and report on usage and performance of our services and any advertisements displayed on or delivered by or through them (iii) protect against, identify, and prevent fraud and other unlawful activity (iv) create aggregate data about groups or categories of our Users (including advertising audiences), and (v) for us, our partners and third party service providers to deliver, target, offer, market, or personalise advertising relating to our services or the services of our clients and partners (including limiting how often you see an advertisement).
- Required cookies - These cookies are required to enable core website functionality. Strictly necessary cookies or similar technologies: They are essential in order to enable you to move around Howtomove website and use its features, such as accessing interactive areas. If you disable these cookies, some or all of the Howtomove website features may not work.
- Performance cookies - These cookies allow us to analyze usage of our services so we can measure and improve performance. Performance cookies or similar technologies: They collect information about how you use our services, so that we can analyze traffic, understand users' interactions, and improve the relevant service. Our emails and newsletters may contain a ‘web pixel’ to let us know how you have interacted with what we have sent you. We may use third party service providers such as Google Analytics for this purpose who may use their own cookies or similar technologies. You can find out more information by clicking on the Google Analytics cookies usage resource link: https://tools.google.com/dlpage/gaoptout?hl=en
- Functionality cookies. Functionality cookies or similar technologies: These allow Howtomove website to remember choices you make (such as your username or the region you are in) and provide enhanced, more personalized features, including personalized content.
- Advertising cookies - these cookies are used by advertising companies to serve ads that are relevant to your interests. Social media cookies or similar technologies: These are used when you share Personal Data using interactive areas on Howtomove website, or when you link your account or engage with our content on or through a social media platforms, such as Facebook or Twitter.
7.3. For digital services in some jurisdictions, including the EEA, you may learn more information about our use of cookies and other technologies, and provide or withdraw consents, or set your cookie preferences and in some cases object legitimate interest purposes for processing your Personal Data, by clicking Manage Cookies+ or otherwise adjusting cookie preferences. These settings are accessible on a site or app specific basis, at any time through the ‘Manage Cookies+’ link or a similar link located on webpages or in application settings. You may also use your app/browser settings to set your cookie preferences.
7.4. To enable or disable the collection of precise location information from your mobile device through our mobile apps , you can access your mobile device settings and choose to limit that collection. You may also limit the collection of precise location information from websites through browser settings.
8. GDPR
8.1. General Data Protection Regulation Privacy Statement (“GDPR Statement”) applies to persons in the European Economic Area (“EEA”), including those based in the United Kingdom. GDPR Statement supplements our Privacy policy; however, where our Privacy policy conflicts with the GDPR Statement, the GDPR Statement will prevail as to persons located in the EEA.
8.2. Personal Data Rights Under GDPR. By using our services, and/or otherwise visiting and/or using Howtomove website, it shall be deemed that you’ve provided us with rights to collect, process, store and otherwise use your Personal Data in accordance with this Privacy Policy. If you want to restrict and/or withdraw this consent, please read the following clauses and subclauses within this chapter 8.
8.2.1. The right to request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you.
8.2.2. The right to request correction of your Personal Data if it is inaccurate. You may also supplement any incomplete Personal Data we have, taking into account the purposes of the processing.
8.2.3. The right to request deletion of your Personal Data if:
- your Personal Data is no longer necessary for the purposes for which we collected or processed them; or
- you withdraw your consent if the processing of your Personal Data is based on consent and no other legal ground exists; or
- you object to the processing of your Personal Data and we do not have an overriding legitimate ground for processing; or
- your Personal Data is unlawfully processed; or
- your Personal Data must be deleted for compliance with a legal obligation.
8.2.4. The right to object to the processing of your Personal Data. We will comply with your request, unless we have a compelling overriding legitimate interest for processing or we need to continue processing your Personal Data to establish, exercise, or defend a legal claim.
8.2.5. The right to restrict the processing of Personal Data, if:
- the accuracy of your Personal Data is contested by you, for the period in which we have to verify the accuracy of the Personal Data; or
- the processing is unlawful, and you oppose the deletion of your Personal Data and request restriction; or
- we no longer need your Personal Data for the purposes of processing, but your Personal Data is required by you for legal claims; or
- you have objected to the processing for the period in which we have to verify overriding legitimate grounds.
8.2.6. The right to data portability. You may request that we send the Personal Data to a third party, where feasible. You only have this right if it relates to Personal Data you have provided to us where the processing is based on consent or necessity for the performance of a contract between you and us, and the processing is conducted by automated means.
8.2.7. You also have the right to lodge a complaint before your national data protection authority.
8.3. You will not usually have to pay a fee to access your Personal Data (or to exercise any of the other rights described in this Statement). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.
8.4. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). To the extent you use a third party to submit a data request on your behalf, we may need to take reasonable steps to verify the authenticity of the request. These are security measures to ensure that Personal Data is not disclosed to any person who has no right to receive it. In an effort to speed up our response, we may also contact you to ask you for further information in relation to your request. To exercise your rights you can file a request by clicking (technical support)
8.5. International Transfers
8.5.1. Your Personal Data may be stored or transferred to countries outside the EEA and the UK for the purposes described in this Statement. When we store or transfer your Personal Data outside the EEA and the UK, we take the following precautions to ensure that your personal information is properly protected:
Whenever we store or transfer your Personal Data outside the EEA and the UK, we will do so in accordance with applicable law, and we will ensure a similar degree of protection is afforded to it by implementing appropriate safeguards. Transfers of Personal Data are made:
- to a country recognised by the European Commission as providing an adequate level of protection ; or
- to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection.
8.5.2. By using our services, you understand that your Personal Data may be transferred to our facilities and those third parties with whom we share it, as described in this Privacy Policy.
9. Dispute Resolution
9.1. Before going to court with a lawsuit regarding disputes arising from relations between the User and the Administration and/or the Company, it is mandatory to present a claim (a written proposal or proposal in electronic form about voluntary dispute resolution) to the other party – recipient of the claim.
9.2. The recipient of the claim must notify the claimant in writing or electronically about the results of the claim review within 30 calendar days from the day of receiving the claim.
9.3. If an agreement is not reached, the dispute will be referred to the Basic Court of Kotor, Montenegro (Osnovni sud Kotor, Montenegro).
9.4. The current legislation of Montenegro applies to this Privacy Policy and the relations between the User and the Administration.
10.1. The Administration has the right to make changes to this Privacy Policy without the User's consent.
10.2. A new Privacy Policy comes into force from the moment it is published on the Howtomove website, unless otherwise provided by the new edition of the Privacy Policy.
10.3. All suggestions or questions regarding this Privacy Policy should be addressed to:
Falicon DOO Budva, Montenegro
Andrei Raskovalkin, CEO
10.4. The current Privacy Policy is posted on the page at https://howtomove.help/en/policy.
10.5. In case of discrepancies between the different languages versions of this Privacy Policyany, the English version will prevail.
Updated: [February 14, 2024]
Budva, Montenegro.