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Effective date: May 21, 2019
Individual entrepreneur I. Shkirya ("us", "we", or "our") operates the https://act-contract.com/ website (the "Service").
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
We take seriously the issue of confidentiality of information of our clients and site visitors https://act-contract.com/ (hereinafter referred to as “you”, “site visitors”). We call personalized information containing personal data (for example, name, login or company name) of the site visitor, as well as information about the actions you perform on https://act-contract.com/. We call anonymous the data that cannot be uniquely identified with a specific site visitor (for example, site attendance statistics).
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on a User’s device.
Data Processor (or Service Providers)
Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
Data Subject is any living individual who is the subject of Personal Data.
The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
Information Collection And Use
We collect several different types of information for various purposes to provide and improve our Service to you.
This document determines the Service’s policy in relation to the processing of personal data and applies to all information that the Service may receive from Users during its use of the Service, products or services provided by the Service, and in the course of any agreements with the User.
Authorization on the site and use of the site means the unconditional acceptance of the User with this Policy and the conditions for processing personal information specified in it. In case of disagreement with these conditions, the User must refrain from using the Service.
This policy has been developed in accordance with the applicable legislation, the legislation of the Russian Federation on personal data, as well as the General Data Protection Regulation of the European Union.
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). The provision of personal data is possible both directly to us and by providing us with access to personal user data contained in third-party services, including social networks.
Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
- User photo
- Date of birth
- Place of birth
- ID date of issue
- Payment details
The service assumes that the User provides reliable and sufficient personal data. The Service has the right to make changes to this Policy. The new version of the Policy comes into force from the moment of its publication. The current edition is always available on the page at: https://act-contract.com/privacy_policy
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
We may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use our Service.
We use Session Cookies to operate our Service, for security purposes,to remember your preferences and various settings.
Use of Data
- We use the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer.
We use the personalized information of a specific visitor of the site solely to ensure the quality of the provision of services and their accounting. We do not disclose personal data of one site visitors to other visitors.
We never publish personal information in the public domain. The only exceptions are situations when the provision of such information to authorized state bodies is prescribed by the current legislation of the Russian Federation and other applicable legislation. We publish and distribute only reports based on the collected anonymous data. At the same time, reports do not contain information on which it would be possible to identify personalized data of service users. We also use anonymous data for internal analysis, the purpose of which is to develop products and services of the Service.
Retention of Data
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Principles of personal data processing
- The processing of personal data is carried out in a lawful and fair manner.
- The processing of personal data is limited to the achievement of specific, predetermined and legitimate goals. It is not allowed to process personal data incompatible with the purposes of collecting personal data.
- It is not allowed to merge databases containing personal data that are processed for purposes that are incompatible with each other.
- Only those personal data that are suitable for processing are subject to processing.
- The content and volume of processed personal data correspond to the stated processing objectives. The processed personal data are not redundant in relation to the stated processing objectives.
- The processing of personal data ensures the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the stated purposes of their processing.
- Personal data is stored in a form that allows determining the subject of personal data not longer than the purpose of processing personal data, unless the period for storing personal data is set by applicable law, contract, to which the beneficiary or guarantor for which is the subject of personal data. The processed personal data shall be destroyed or depersonalized upon the achievement of the processing aims or in case of loss of the need to achieve these aims, unless otherwise provided by applicable law.
Personal data processing conditions
- The processing of personal data is carried out in compliance with the principles and rules established by applicable law, the Federal Law “On Personal Data” and the General Data Protection Regulation of the European Union. The processing of personal data is permitted in the following cases:
- the processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
- the processing of personal data is necessary to achieve the aims stipulated by the applicable law, or to implement and execute the functions, powers and duties assigned to the controller of data by the applicable legislation;
- the processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the applicable legislation on enforcement proceedings;
- the processing of personal data is necessary for the execution of the contract, the party or beneficiary or guarantor of which is the subject of personal data;
- the processing of personal data is necessary to protect the life, health or other vital interests of the subject of personal data, if obtaining the consent of the subject of personal data is impossible;
- the processing of personal data is necessary to exercise the rights and legitimate interests of the data controller or third parties, or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data;
- the processing of personal data is carried out for statistical or other research purposes, subject to the mandatory depersonalization of personal data. An exception is the processing of personal data in order to promote goods, works, services on the market by making direct contacts with a potential consumer through communication tools;
- the processing of personal data is carried out, access of an unlimited number of persons to which is provided by the subject of personal data, or at his request (hereinafter referred to as personal data made publicly available by the subject of personal data);
- the processing of personal data subject to publication or mandatory disclosure in accordance with applicable law
- biometric personal data (information that characterizes the physiological and biological characteristics of a person, on the basis of which his identity can be established and which are used by the data controller to identify the identity of the subject of personal data) is not processed by the Service.
Transfer Of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside European Union and/or Russia and choose to provide information to us, please note that we transfer the data, including Personal Data, to above-mentioned countries and process it there.
The Service is entitled to entrust the processing of personal data to another person, unless otherwise provided by applicable law, on the basis of an agreement concluded with this person (hereinafter referred to as the data controller order). At the same time, the Service obliges the person who processes personal data on behalf of the Service to comply with the principles and rules for processing personal data provided for by applicable law. If the Service entrusts the processing of personal data to another person, the Service is liable to the subject of personal data for the actions of the said person. The person who processes personal data on behalf of the Service is liable to the Service. The Service undertakes and obliges other persons who have obtained access to personal data not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by applicable law.
In accordance with the requirements of applicable law, the Service undertakes to:
- Provide the subject of personal data upon his request with information regarding the processing of his personal data, or legally provide a refusal.
- At the request of the subject of personal data, to update the processed personal data, to block or delete, if the personal data are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing.
- In the event that the goal of processing personal data is achieved, immediately cease processing of personal data and destroy the corresponding personal data within a period not exceeding thirty days from the date of attaining the goal of processing personal data, unless otherwise provided by the contract, the party of which, the beneficiary or guarantor for which is the subject of personal data, another agreement between the Service and the subject of personal data or
- In case of a withdrawal by the subject of personal data of consent to the processing of its personal data, stop processing of personal data and destroy personal data within a period not exceeding thirty days from the date of receipt of the specified review, unless otherwise provided by agreement between the Service and the subject of personal data. The Service is obliged to notify the subject of personal data about the destruction of personal data.
- In the event that a subject's request to terminate the processing of personal data is received in order to promote goods, works, services on the market, immediately stop processing personal data.
Measures to ensure the security of personal data during their processing
When processing personal data, the Service takes the necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions in relation to personal data.
Ensuring the security of personal data is achieved, in particular:
- identification of threats to the security of personal data when it is processed in personal data information systems;
- the use of organizational and technical measures to ensure the security of personal data when processing them in personal data information systems necessary to meet the requirements for the protection of personal data, the performance of which ensures the levels of personal data protection established by applicable legislation.
- application of the procedure for assessing the compliance of information security tools in the prescribed manner;
- evaluating the effectiveness of measures taken to ensure the security of personal data prior to the commissioning of the personal data information system;
- detecting unauthorized access to personal data and taking action;
- restoration of personal data modified or destroyed due to unauthorized access to it;
- control over measures taken to ensure the security of personal data and the level of security of personal data information systems.
Disclosure Of Data
Disclosure for Law Enforcement
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
- We may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Service
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the right:
- To access and receive a copy of the Personal Data we hold about you
- To rectify any Personal Data held about you that is inaccurate
- To request the deletion of Personal Data held about you
You have the right to data portability for the information you provide to us. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it. Please note that we may ask you to verify your identity before responding to such requests.
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. We are not responsible for the accuracy and completeness of the information posted on third-party websites, and do not undertake any obligation to maintain the confidentiality of the information you post on such sites.
Our Service does not address anyone under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us.
If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.