Effective date: July 17, 2019
Company’s Managing Director was appointed as the data protection officer. Please send any queries or comments by email to firstname.lastname@example.org.
Data Protection Officer
Alexander Ivanov, Managing Director
“Personal Information” or “Personal Data” means any information which relates to a living, identifiable person. It can include names, addresses, telephone numbers, email addresses etc., but it is wider than that and includes any other information relating to that person or a combination of information which, if put together, means that the person can be identified.
“Processing” covers all activities relating to the use of personal data by an organization, from its collection through to its storage and disposal and everything in between.
1.2 Principles for Processing Personal Information
We take protecting of your personal information seriously, and we recognize we have a duty of care to the people whose data we process. We will accurately collect and securely process personal information only when it is necessary, and when we do, we will make it clear why we are collecting it and how it will be stored and used. We will not share your personal information with anyone else without your permissions other than when we are required to do so by the law.
2. Collecting Personal Information
We may collect, store and use the following types of personal information:
- Information about your computer including your IP address, geographical location, browser type and version, and operating system;
- Cookies and URL information about date and time of your visits of this Site, including the referral source, length of visit, information for which you searched and which you viewed;
- Information that you enter while using the services on our Site;
- Information that is generated while using our Site, including when, how often, and under what circumstances you use it;
- Information relating to anything you ordered, products and services you use, or transactions you make with us, which includes your name, address, telephone number, email address, your account details with financial services providers;
- Information contained in any communications that you send to us by post, email, through our Site or other electronic channels, like messaging applications, including its communication content and metadata;
- any other personal information that you send to us.
3. Processing Personal Information
- Administering our Site and business;
- Personalizing our Site for you;
- Enabling your use of the services available on our Site;
- Sending you goods and services ordered from us;
- Processing statements, invoices, and payment requests and collecting payments from you;
- Notifying you non-marketing commercial communications;
- Sending you email notifications that you have specifically requested;
- Sending you marketing communications relating to our business or the businesses of carefully-selected third-parties which we think may be of interest to you;
- Dealing with inquiries and complaints made by or about you relating to our Site;
- Keeping our Site secure and prevent fraud;
- Verifying compliance with the terms and conditions governing the use of our Site;
If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the license you grant to us.
3.1 Basis for Processing
Where we obtain consent from you for personal data processing operations it is the legal basis for their processing.
If processing personal data is necessary for the performance of a contract with you it serves as a legal basis to do so. This also applies to processing that is necessary in order to take steps prior to entering into such a contract.
We may process personal information on the legal basis of compliance with legal obligations to which our company is the subject.
We process personal information on the legal basis of our legitimate interests to keep our records accurate and updated and/or to study how customers use our products and services by reaching out to you for a review or with an invitation for a survey.
3.2 Your Consent
Where the legal basis for us processing your personal data is that you have provided your consent, you may withdraw your consent at any time. There are no penalties for withdrawing your consent. If you withdraw your consent, this will not make processing which we undertook before you withdrew your consent unlawful.
You can withdraw your consent by contacting the Data Protection Officer, whose details are provided above.
4. Retention of Personal Information
Personal data that we process for any purposes shall not be kept for longer than is necessary for those purposes. Personal data related to customers and /or partner accounts is retained until that person or partner closes their account with us.
Notwithstanding the above, we will retain the data to the extent that we are required to do so by law and in order to establish, exercise, or defend our legal rights.
5. Disclosing Personal Information
We may disclose your personal information to our staff, partners, suppliers, or subcontractors as reasonably necessary for the purposes of fulfilling a contract with you or for delivery of our products and services to you.
We may disclose your personal information:
- to the extent that we are required to do so by law;
- in order to establish, exercise, or defend our legal rights.
We share Google Analytics and Adwords data collected on our Site with Google. Please note that these data do not fall under personal information category and can always be deactivated via the Google Display Settings.
6. Information Transfers
7. Data Rights
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive a copy of your data and check that we are lawfully processing it.
- Request correction of your data. This enables you to ask us to correct any incomplete or inaccurate information we hold about you.
- Request erasure of your data. This enables you to ask us to delete or remove your data where there is no good reason for us to continuing to process it. You also have the right to ask us to remove your data where you have exercised your right to object to processing.
- Object to processing of your data where we are processing it to meet our legitimate interests and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your data for marketing communications purposes.
- Request the restriction of processing of your data. This enables you to ask us to suspend the processing of your data, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your data to another party.
Depending on the circumstances and the nature of your request it may not be possible for us to do what you have asked, for example, where there is a performance of the contract requirement for us to process your data and it would not be possible to fulfil our legal obligations if we were to stop.
If you want to exercise any of the right described above or are dissatisfied with the way we have used your information, please contact our Data Protection Officer. We will seek to deal with your request without undue delay. Please note that we may keep a record of your communication to help us resolve any issues which you raise.
8. Protecting Personal Information
We maintain administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Service providers and contractors who might have access to your data in order to provide services on our behalf will be contractually obliged to keep such data in confidence, provide adequate data security measures, and may not use that data for any other purpose.