Date: 12 December 2023
2. Who Processes the Information
To ensure your use of the Sites and Services, your Personal Information is collected and used by the Company.
The Personal Information of customers may be processed by the Company on behalf of the user or by the user on behalf of the Company, depending on who initially provided such information.
If the customer's Personal Information is initially provided to the user, the latter must ensure the existence of grounds for the Company to process such information in the course of executing the user's instructions, including obtaining the customer's consent to the processing of their Personal Information by third parties, if applicable.
This Policy serves as the sole document formalizing mutual instructions between the Company and users, sufficient to create legal consequences resulting from the conclusion of a contract for the processing of Personal Information.
The entity processing Personal Information based on instructions is subject to all applicable data security requirements during processing, including the provisions of this Policy.
In the course of executing instructions, only the Personal Information that is processed in accordance with the provisions of this Policy, by the methods provided for in this Policy, and to achieve the purposes stated in this Policy, is subject to processing.
3. Purpose of this Policy
Protecting your Personal Information and your privacy is extremely important to the Company. Therefore, when you use the Sites and Services, the Company protects and processes your Personal Information in strict compliance with applicable legislation.
In fulfilling our obligations to protect your Personal Information, in this Policy, we would like to inform you most transparently about the following:
(a) why and how the Company collects and uses ("processes") your Personal Information when you use the Sites and/or Services;
(b) the role and responsibilities of the Company as a legal entity deciding why and how to process your Personal Information;
(c) the tools you can use to reduce the amount of Personal Information collected by the Company about you;
(d) your rights within the processing of Personal Information.
4. What Personal Information the Company Collects About You
The Company may collect the following categories of Personal Information about you when you use the Sites and Services:
(i) Personal information provided by you during registration (account creation), such as your name, phone number, address, and age;
(ii) electronic data (HTTP headers, IP address, cookie files, web beacons/pixel tags, browser identifier information, hardware and software information);
(iii) date and time of access to the Sites and/or Services;
(iv) information about your activity while using the Sites and/or Services (e.g., search history, files stored in the Company's systems);
(v) information about geolocation;
(vi) other information about you necessary for processing in accordance with the terms regulating the use of specific Sites or Services of the Company.
Additionally, the Company uses cookie files and web beacons (including pixel tags) to collect Personal Information and associate such personal information with your device and web browser (see section 10 of this Policy).
The Company does not intentionally collect sensitive Personal Information (such as racial or ethnic origin, political views, health information, and biometric data). However, you may voluntarily provide it to the Company, and in such a case, the Company will process it exclusively within the scope of providing you with services (for example, if you make health-related search queries), and in case of inability to process for the intended purposes, will delete it as if the information was accidentally received.
You are not obligated to provide the Company with Personal Information that is not objectively necessary for the normal use of the Sites and Services.
The Company does not profile users, nor does it use the obtained Personal Information for automated decision-making that affects the rights and/or legitimate interests of users or for targeting purposes.
5. Legal Basis and Purposes of Processing Your Personal Information
The Company is not authorized to process your Personal Information without sufficient legal grounds. Therefore, the Company processes your Personal Information only if:
(i) processing is necessary to fulfill contractual obligations of the Company to you, including ensuring the operation of the Sites and Services (for example, providing you with search results based on your search queries);
(ii) processing is necessary to comply with legally established obligations;
(iii) when applicable legislation provides, processing is necessary to safeguard the legitimate interests of the Company, provided that such processing does not significantly impact your interests, fundamental rights, and freedoms. Please note that when processing your personal information on this basis, the Company will always seek to balance its legitimate interests with the protection of your privacy.
The Company processes your Personal Information to safeguard its legitimate interests, for example, in the following cases:
(a) to better understand how you interact with our Sites and/or Services;
(b) to improve, modify, personalize, or otherwise enhance the Sites and Services for the benefit of all users;
(iv) for specific purposes or in accordance with applicable law, the Company may request your separate consent to process your Personal Information.
The Company hereby informs you, and you confirm that you have no obligations to provide the Company with any Personal Information when you use the Sites or Services; the provision of information is based solely on your free will. However, you are aware that without providing Personal Information, your use of the Sites and Services will be limited to the extent that their full use for their intended purpose is objectively impossible without providing Personal Information.
The Company always processes your Personal Information for specific purposes and only the Personal Information related to achieving such purposes. In particular, we process your Personal Information for the following purposes:
(i) providing you access to the Sites and/or Services (including providing search results in response to your search queries);
(ii) providing access to your account;
(iii) communicating with you to send notifications, requests, and information related to the operation of the Sites and Services, fulfilling agreements with you, and processing your requests and applications;
(iv) enhancing the usability of the Sites and Services;
(v) creating new products, utilities, and offerings of the Company;
(vi) protecting your rights and the rights of the Company;
(vii) collecting, processing, and presenting statistical data, big data, and other research.
The Company disseminates Personal Information solely to achieve the stated purposes of its processing in the corresponding volumes. Personal information regarding a specific individual cannot be disseminated in cases where it contradicts the Company's reasonably understood interests and expectations of such an individual.
6. How the Company Protects Your Personal Information
In most cases, Personal Information is processed automatically without access by any of the Company's employees. In the event that such access is needed, it is provided only to those Company employees who require it to perform their tasks.
The Company has also implemented sufficient technical and organizational measures to protect Personal Information from unauthorized, accidental, or unlawful destruction, loss, alteration, wrongful use, disclosure, or access, as well as other unlawful forms of processing. These security measures have been implemented in consideration of the modern level of technology, the cost of their implementation, risks associated with processing, and the nature of the Personal Information.
Storage of your Personal Information is carried out by the Company without the use of removable and other non-fixed data carriers that can be transported outside the protected perimeter.
In the event of an incident related to Personal Information, within one day from the moment of identifying the incident, the Company:
-initiates an internal investigation into the incident;
-notifies data subjects and competent authorities of the incident;
-documents the security breach by recording entries in the internal register;
-takes initial measures to eliminate the incident (localize its negative consequences).
As the Company's main activities are not associated with processing Personal Information requiring regular and systematic monitoring of subjects on a large scale, the Company does not appoint a data protection officer.
7. Who Else Has Access to Your Personal Information and to Whom It May Be Disclosed
The Company may disclose Personal Information to third parties to achieve the purposes stated in section 5 of this Policy. The Company takes available measures to maintain the level of protection of Personal Information when transferring it in accordance with this section.
Personal Information may be disclosed to:
(i) public entities authorized by applicable legislation to access Personal Information;
(ii) individuals, regarding the transfer of Personal Information to whom you have given your consent, or the transfer of Personal Information to whom is evidently in your interests and corresponds to your reasonable expectations, as understood by the Company, including persons monitoring user behavior when using the Sites and Services (operators of metric programs).
The Company cautions that in some cases, the Sites and Services may contain links to third-party forms for collecting Personal Information. In such cases, it is recommended to ensure that the entity to which you are providing Personal Information through the completion of a third-party form complies with applicable legislation on processing and ensuring the security of Personal Information during processing.
The Company guarantees that you will be informed about the fact of disclosing Personal Information to a third party (in cases where such disclosure is not related to the need to provide you with high-quality services, you were not informed in advance about the disclosure, and could not reasonably expect it), as well as the reasons for such disclosure. Relevant facts of disclosure are documented by recording entries in the internal register.
8. How Long We Retain Your Personal Information
The Company deletes your Personal Information within 7 days from the day when the purposes outlined in the Policy are achieved, or when achieving them has objectively and obviously become impossible. The Company takes reasonable measures to ensure the deletion or anonymization of information transferred to third parties in accordance with the Policy.
You can also independently delete Personal Information using your account before the processing purposes are achieved, understanding that this will result in limitations to the functionality for which the Personal Information is objectively necessary.
Accidentally obtained Personal Information is deleted by the Company immediately upon discovering the accidental nature of the initial processing.
The documentary confirmation of the fact of deleting Personal Information is carried out in accordance with applicable legislation.
9. Your Rights
9.1. What Rights You Have
You have the right to access your Personal Information processed by the Company in accordance with this Policy. Access to your Personal Information is either provided by you independently through the use of your account or the Company provides access to Personal Information at your request within a reasonably required period. When determining the method of fulfilling a request for access, the Company follows your preferences if their implementation is not obvious and disproportionately burdensome and/or resource-intensive. In the latter case, and in the absence of preferences regarding the method of providing access in the request, it is provided in a manner determined by the Company, taking into account established practice. The verification of the identity of the subject exercising the right of access is carried out by the Company itself if the volume of Personal Information processed by it allows establishing identity with a reasonable degree of reliability. Otherwise, the Company has the right to request the minimum amount of information necessary for verification purposes. The facts of exercising the right of access are documented by the Company by recording entries in the internal register.
If you believe that any information that the Company holds about you is incorrect or incomplete, you can log into your account and correct your Personal Information independently or send a request to the Company for correction, which is to be executed within a reasonably required period.
In this case, as well as in other cases of changes to Personal Information, the Company guarantees the corresponding updating of the information transferred to third parties if the conditions for transferring such information imply the need to keep it up to date.
You also have the right, in particular:
-to demand the deletion of your Personal Information or its part, as well as to withdraw your consent to the processing of -your Personal Information;
-to demand restrictions on the processing of your Personal Information;
-to the portability of your Personal Information by transferring it in a structured, machine-readable format to you or -another person (in the latter case, if it is technically feasible);
-to object to the processing of your Personal Information;
-to challenge any actions (inaction) of the Company related to the processing of Personal Information in the manner provided by applicable law.
The Company informs you that the implementation of the right to withdraw consent does not affect the lawfulness of processing prior to the withdrawal, nor does it deprive it of legitimacy.
9.2. How You Can Exercise Your Rights
The rights that you can exercise without the involvement of the Company are carried out by you using your account. To facilitate the exercise of other rights, you can contact the Company using the contact information provided on the Websites (in the Services). Inquiries related to the exercise of the rights of subjects of Personal Information are considered by the Company without undue delay, but in any case, within 5 business days from the date of receiving the inquiry, unless a shorter review period is specifically provided or if there is a legitimate basis under applicable law for extending the review period. A response to the inquiry is sent to the applicant before the expiration of the review period by the same means through which the inquiry was sent, or, if that is impossible or excessively difficult, by another means that ensures no less prompt delivery and no less reliable transmission channel.
10.1 What Are Cookies and Why Does the Company Use Them
Cookies are small text files placed on the device you use to access the Websites. They contain information gathered from your device and sent back to the Websites each time you visit them to remember your actions and preferences over time.
The following types of cookies are used on the Websites:
Strictly Necessary Cookies / Technical Cookies: These cookies are essential for the operation of the Websites and providing you with Services. They also allow the Company to identify your hardware and software, including your browser type.
Statistical / Analytical Cookies: These cookies enable the recognition of users, counting their number, and collecting information such as your operations on the Websites and Services, including information about the web pages you have visited and the content you have received.
Technical Cookies: These cookies collect information about how users interact with the Websites and/or Services, allowing the identification of errors and testing new features to improve the performance of the Websites and Services.
Functional Cookies: These cookies enable the provision of specific features to facilitate your use of the Websites, such as saving your preferences (such as language and location).
(Third-party) Tracking Cookies: These cookies collect information about users, traffic sources, visited pages, and publications displayed to you, as well as the page you came from. They are used for statistical and research purposes.
The Company may also use web beacons (pixel tags) to access cookies previously placed on your device for the following purposes:
(i) Identifying your actions on the Websites and during the use of the Services by accessing and using cookies stored on your device.
(ii) Collecting statistical information related to the operation of the Websites, Services, or products, utilities, and offers of the Company.
10.2 How Long Cookies Are Stored on Your Device
The Company uses information contained in cookies only for the purposes mentioned above, after which the collected data will be stored on your device for a period that may depend on the corresponding type of cookie but does not exceed the period necessary to achieve its purpose, after which it will be automatically deleted from your system.
10.3 Who Else Has Access to Information Contained in Cookies
Personal information collected through cookies placed on your device may be transferred and accessible to the Company and/or third parties as specified in section 7 of this Policy.
11. Age Restrictions
The Company's Websites and Services are not intended for individuals under the age of 18 (hereinafter referred to as "Children"). The Company takes reasonable measures to determine the age of individuals intending to use the Websites and Services.
If you are a parent or guardian and know that your children, despite the measures taken by the Company, have provided Personal Information, please contact the Company. If the Company becomes aware of the collection of Personal Information from children without parental (guardian) consent, the Company takes steps to delete such Personal Information.
12. Update of this Policy
The Company undertakes to inform you of changes made to this Policy that, from the Company's point of view, are or may be subjectively significant to you. Notification is provided through the interface of the Websites and Services. Changes take effect no earlier than one month after the date when the notice by the Company could have been initially perceived by you. Archived versions of this Policy are available on the Websites for informational purposes.
13. Questions and Suggestions
The Company welcomes your questions and suggestions regarding the implementation or modification of this Policy. Please send a letter to: firstname.lastname@example.org. You can also use this address to submit requests regarding the exercise of your rights or complaints about the inaccuracy of your Personal Information or the illegality of its processing.