This policy for the processing of personal data (hereinafter the Politics) Smart Engines Service, taxpayer identification number 7728328449, KPP 772801001, Primary State Registration Number 1167746085297, address: Prospect 60-Letiya Oktyabrya, 9, Moscow, 117312, Russia (hereinafter the Company) establishes the scope, goals and methods of processing personal data of individuals who are not employees of the Company, and is published in the public domain in accordance with the requirements of the Federal Law of the Russian Federation On Personal Data No. 152-FZ of July 27, 2006
1. Legal basis for processing of personal data.
The legal justification for the processing of personal data are: article 6 of the Federal Law of the Russian Federation On Personal Data No. 152-FZ of July 27, 2006 and a consent of the personal data subject.
2. User consent for processing of personal data.
A user of the site expresses his consent to the processing of personal data for the purposes and scope defined by this Policy by sending a message through feedback forms.
The personal data subject expresses his consent to the processing of his personal data in the level of to create an account.
A user of the Company’s website can subscribe to receive newsletters by e-mail, if the website provides such an opportunity. The newsletter may contain information about news, analytical materials, events conducted by the Site, etc. A user agrees to receive such newsletters by filling in the e-mail field. The user may at any time withdraw his consent to receive the newsletter. The ability to unsubscribe from the newsletter is provided to a user in each letter.
3. Purpose for processing of personal data.
The purpose of processing personal data is to provide the user with information about the Company, including the conditions for concluding contracts, services, passing promotions and special offers; a quality assessment of the service provided by the Company and improving the quality of customer service of the Company; performance of a contract; the provision of services; accounting of services provided to customers to provide settlements, handling of complaints and grievances of the Company’s clients.
A personal data are not processed, if a site user just browsing the Company’s site.
4. The volume of processing of personal data.
The Company processes the following personal data of individuals non-employees of the Company: last name, first name, patronymic, email address, phone number, address.
The site uses cookie processing technologies – these are small text files in which the browser writes data from the sites visited by the user. These data are used to collect information about the actions of visitors to the site, to improve the quality of its content and opportunity.
The user can change the settings in the configurations of his browser so that the browser does not save all cookies, and also notifies them of sending, at any time. Some services and functions of the site may stop working or work incorrectly in this case.
5. Confidentiality of personal data.
The site does not disclose to third parties and does not disseminate the personal data of users of the site without their consent, except as otherwise provided by federal law.
6. The time for processing of personal data.
The personal data provided by the user is processed until the liquidation (reorganization) of the Company.
7. Rights of the subject of personal data.
The personal data subject has the right to send a written request to the Company for information, that regarding the processing of his personal data as required by article 14 of the Federal Law of the Russian Federation On Personal Data No. 152-FZ of July 27, 2006.
This request may be sent to the address of the location of the Company: Prospect 60-Letiya Oktyabrya, 9, Moscow, 117312, Russia
8. The protection of personal data.
The Company has been taking measures that are necessary and sufficient to respond to the obligations of the Federal Law of the Russian Federation On Personal Data No. 152-FZ of July 27, 2006 and legislations, that have been accepted in accordance with it.
The Company independently determines the composition and list of measures that are necessary and sufficient to respond to the obligations, in particular:
a) appointed a person who responsible for the organization for processing of personal data;
b) drafted and approved local acts on the processing and protection of personal data;
c) legal, organizational and technical measures are applied to ensure the security of personal data:
– threats to the security of personal data are identified during their processing in personal data information systems;
– the rules for access to data processed in the personal data information system are established and registration and accounting of all actions performed with personal data in the personal data information system is provided;
d) the control over measures taken to ensure the security of personal data and the level of security of personal data information systems is carried out;
e) assesses the damage that may be caused to the personal data subject in case of violation of the requirements of the current legislation of the Russian Federation, the ratio of the specified harm and the measures taken by the Company aimed at ensuring the fulfillment of obligations stipulated by the current legislation of the Russian Federation;
f) conditions that exclude unauthorized access to material carriers of personal data and ensure the safety of personal data are respected;
g) Company employees directly processing personal data are familiar with the provisions of the legislation of the Russian Federation on personal data, including the requirements for the protection of personal data, local acts on the processing and protection of personal data.
The Company maintains an appropriate IT environment and takes all measures necessary to prevent unauthorized access in order to ensure the confidentiality of information and the protection of personal data.
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Smart Engines guarantees that the provided information will not be made public and will be used only internally.