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PRIVACY 

POLICY

 

This Policy has been established in conformity with the requirements of the Law on Personal Data of the Russian Federation and defines the procedure for User's personal and any other data processing, User's acceptance to such processing, as well as measures to ensure the security and confidentiality of data.

 

TERMS AND DEFINITIONS

 

The Law on Personal Data – Federal Law of the Russian Federation dated 27.07.2006 No. 152-FZ "On Personal Data", which defines the rights and obligations of the Parties regarding the User's personal data turnover.

 

 

 

Policy – this document, that defines the procedure of processing the User's personal and any other data in according with the Law on Personal Data.

 

 

User – any person who has accepted the Agreement and uses the Product in accordance with the terms and conditions set out therein.

 

Copyright holder – Avchian Tigran, the company who owns the Product and provides the User with the opportunity to use it under the terms of the Agreement.

 

Product – a set of results of intellectual activity, the exclusive right to which belongs to the Copyright holder, as well as the related services of the Copyright holder. The product can be provided to the User via the "SaaS" model, as well as by granting the right to use the application.

 

 

 

 

Agreement – the user agreement (contract) on the use of the Product, setting out the rights and obligations of the Parties, and located at https://www.cosanostra.pro/privacy-policy

 

Parties – User and Copyright holder jointly.

 

Account – User's personal account in the Product, which contains information about the User, the User's data and also allows the use of certain functionalities of the Product, depending on the User's role in the Product.

 

 

Other terms and definitions have the meanings as defined for them by the laws of the Russian Federation, including but not limited to the Law on Personal Data, as well as the business practices accepted in the scope of the Product.

 

  1. THE SUBJECT OF POLICY

 

  1. The Policy governs the Copyright holder's activities in relation to all User data, including personal data that the Copyright holder and/or its affiliates may obtain when the User is using the Product. 

 

 

  1. The Copyright holder also acts as a personal data controller while processing User’s personal data under the Policy, as set out in the Law on Personal Data, and the User is the subject of the personal data.

 

 

  1. The Policy does not regulate the processing of publicly available data, including, but not limited to, publicly available data about User and data about the User's organization that may be represented by User under the Agreement.

 

  1.     II. TYPES OF DATA,

PURPOSES AND METHODS

OF DATA PROCESSING

 

  1. The Copyright holder may collect and process the following personal data: name, surname, middle name of the User; e-mail address; telephone number, image of the User; location data (geolocation), payment card data, other payment information provided by the User and received from other persons involved in the payment transaction using the Product; technical information – HTTP headers, IP address, cookies, browser data, hardware and software information, network data; data about the behavior when using the Product.

 

 

 

 

 

 

  1. The Copyright holder may also collect and process impersonal data about the User, as well as other data which are not personal data of the User accordingly to the Law on Personal Data, but were placed into the Product by the User (various content of the User and other information).

 

 

  1. The purposes of collecting and processing personal data and other User data are:

  • conclusion and execution of the Agreement in the interests of the User, the beneficiary of which is the User;

 

  • informing the User through available means of communication, sending emails and other notifications (including "push notifications");

 

  • advertising and promotion of other products and services of the Copyright holder;

  • providing the User with an access to the Product and other services of the Copyright holder;

  • collecting statistical information about the Product for the improvement and refinement of the Product;

  • processing payments when using the Product.

 

  1. The Copyright holder collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transmits (dissemination, provision, access), anonymizes, blocks, deletes and destroys personal data.

 

  1. The Copyright holder carries out automated processing of personal data with or without receiving and/or transmitting the information received via information and telecommunication networks.

 

 

  1.     III. PROCESSING RULES

 

  1. Processing of personal data shall be conducted on a lawful and fair basis. Processing of personal data shall be limited to specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection shall not be permitted.

 

 

  1. Databases containing personal data whose processing is incompatible with each other are not permitted to be merged.

 

 

  1. Only personal data that meet the purposes for which it is processed shall be processed.

 

  1. The content and scope of the personal data processed correspond to the stated purposes of processing. Processed personal data shall not be excessive with regard to the stated purposes of its processing.

 

 

  1. The processing of personal data shall ensure the accuracy of personal data, their sufficiency and, where necessary, their relevance with regard to the purposes of personal data processing. The Copyright holder shall take necessary measures and/or ensure that such measures are taken to remove or clarify incomplete or inaccurate data.

 

 

  1. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than the purposes of personal data processing, unless the storage period of personal data is prescribed by law, an agreement to which the personal data subject is a party, a beneficiary or a guarantor. Processed personal data shall be destroyed or depersonalised upon attainment of the processing purposes or if it is no longer necessary to attain such purposes, unless otherwise provided for by the law.

 

  1.     IV. RIGHTS AND OBLIGATIONS 

OF THE PARTIES

 

  1. User has the right to:

  • receive information relating to the processing of their personal data, except in cases provided by the Law on Personal Data. Information shall be provided to the User by the Copyright holder in an accessible form and shall not contain personal data relating to other personal data subjects, unless there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it is set out in the Law on Personal Data;

 

 

 

  • demand that the Copyright holder clarify, block or destroy personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained or unnecessary for the stated purpose of processing, as well as to take statutory measures to protect their rights;

 

 

 

 

  • withdraw consent to the processing of personal data;

  • to appeal to the competent authority for the protection of the rights of subjects of personal data or in court against unlawful acts or omissions of the Copyright holder in the processing of their personal data;

 

  • implement the other rights provided in the Law on Personal Data;

 

 

 

  1. User has the obligations set out in the Law on Personal Data as well as in the Agreement and in this Policy.

 

  1. The Copyright holder has the rights set out in the Law on Personal Data as well as the Agreement and this Policy.

 

  1. The Copyright holder is obliged to process personal data and other data of Users in accordance with the conditions set out in the Law on Personal Data, as well as the Agreement and this Policy.

  2. The Copyright holder is obliged to ensure the confidentiality of the processed data and not to disclose to third parties and not to disseminate personal and other data without the User's consent, unless otherwise provided by applicable law.

 

  1.     V. USER CONSENT

 

  1. Consent to the processing personal data under the terms of this Policy, the User provides to the Copyright Holder directly upon acceptance of the terms of the Agreement by clicking on the checkbox "I accept the terms and conditions of the Agreement and consent to the processing of personal data in accordance with the Privacy Policy" and creating an Account in the Product.

 

  1. The User guarantees that he has read the terms of the Policy, he understands the purposes and procedure for processing his data, incl. personal, as well as the set of the data provided to the Copyright holder.

 

  1. The User provides consent freely, by his own will and in his interest, confirms his legal capacity, and also confirms that he is aware of his legal rights in relation to his personal and other data, which are established by the Policy, the Law on Personal Data and the Agreement.

 

 

  1. Consent provided by the User to the Copyright holder is valid for the duration of the Agreement, unless previously withdrawn by the User. 

 

 

  1. The parties have agreed that if the User's consent provided under the Policy is terminated, the Copyright holder may not be able to fulfil the terms of the Agreement and may unilaterally terminate it.

 

  1.     VI. DATA STORAGE 

AND TRANSFER

 

  1. Processing of personal data of Users from the Russian Federation is carried out in databases located on the territory of the Russian Federation.

 

  1. Processing of personal data of Users from other countries may be carried out both in and outside the Russian Federation.

 

 

  1. Before transborder transfer of personal data, the Copyright holder must ensure that the foreign country to whose territory the transfer of personal data is to be carried out provides reliable protection of the rights of personal data subjects.

 

  1. If the User is located in a territory where his consent is required for the transfer or storage of personal data in another jurisdiction, while using the Product, the User gives the Copyright holder his explicit and unambiguous consent to such transfer or storage and / or processing of his data in other jurisdictions, including the Russian Federation.

 

 

  1. Personal data of the Users shall be stored and processed for as long as it necessary to achieve the purposes of the Policy and the Agreement for which it was collected or to comply with legal and regulatory requirements, but in any case for no less than the duration of the Agreement.

 

 

  1.     VII. MISCELLANEOUS 

 

  1. The Copyright Holder may amend the Policy and other related documents. In the case of amendments to the Agreement, such amendments shall become effective as of the date of releasing of the amended text of the Agreement, unless a different effective date was defined in the new edition of the Agreement.

  2. The Policy supplements the terms and conditions of the Agreement, and constitutes an integral part thereof. In case of any conflict between the Policy and the Agreement, the terms of both documents shall apply insofar as they do not conflict with each other until amended as appropriate.

 

  1. The User independently monitors changes in the Policy and undertakes to stop using the Product in case of disagreement with the new terms of the Policy.

 

  1. The Policy is drawn up in both Russian and English. In case of a discrepancy between the Russian version of the Policy and the English version, the provisions of the Russian version of this Policy shall apply.

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