USER DATA PROTECTION POLICY

 

User – a natural person of age, capable by their actions to acquire the civil rights and independently to implement them, and create for itself the civil duties, to independently perform and be responsible in case of failure, accept the terms of this document and using the services of the Website.

 

Administration – CLICKBANG LP, registered at Suite 2, 5 St. Vincent street, EH3 6SW, Edinburgh, Scotland, which is the sole owner of the site on the basis of private property rights and provides organizational, financial, technical support for the existence and operation of the site.

 

Parties-Administration and Users of the Site.

 

User data protection policy (socr. - "Privacy policy" – - a set of rules for the processing of User data and the interaction of the Parties in this process, as part of the User's use of the Site features.

 

Acceptance is a legal action of the active form of the Party expressing the consent of the Party to the provisions and the rules of processing of the User's data set forth in the privacy Policy. The parties have agreed that such action may be expressed:

 

               (a) by the Administration-by publishing this privacy Policy on the Site;

 

             (b) by the User, in the manner specified in the privacy Policy.

 

General Data Protection Regulation (socr. - "GDPR") - General regulation on the protection of personal data 2016/679 of the European Parliament and the Council of the European Union of 27 April 2016, on the protection of individuals regarding the processing of personal data and on the free movement of such data, as well as the repeal of Directive 95/46 / EC (General data protection rules).

 

Personal data — any factual information that allows you to identify the data subject. Such information includes, but is not limited to, name, location, online ID, or one or more factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity, including, but not limited to, IP addresses, name, email, API tokens, payment information, and HTTP response (status) code.

 

Website – an Internet resource that has a domain name http://spilna.com, under organizational management and owned by the Administration on the terms of private property rights.

 

1.           General terms

 

1.1. This privacy Policy defines the procedure for processing and protection by the Administration of personal data about Users that can be obtained by the Administration when the User uses the services provided through the Site.

 

1.2. When compiling this privacy Policy, as well as in our algorithms for interaction with Users, the requirements of the General Data Protection Regulation And the Federal law "on personal data"are taken into account.

 

1.3. The administration provides its services exclusively to persons who have reached 16 years of age, who are able to acquire civil rights for themselves and independently exercise them.

 

1.4. The administration combines simultaneously two legal status provided by the Rules for the protection of personal data:

 

               (a)the data Controller

 

               (b)the data Processor

 

1.5. In relations With users of the Site, the Administration has a legal status

 

The data controller.

 

1.6. In the relationship of the Site User with third parties, in which the functions of the Site are used, the Administration has the legal status of data Processor

 

1.7. The purpose of this privacy Policy is to ensure proper protection of information about Users, including their personal data, from unauthorized access and disclosure.

 

1.8. The relations related to the collection, storage, distribution and protection of information provided by the User are governed by this privacy Policy. The administration pays special attention to data protection.

 

1.9. The administration informs Users about how it uses the information coming to the Site.

 

1.10. Users who intend to use the Site's functionality for the first time, including in a test format, must first read the provisions of the privacy Policy.

 

1.11. Users who use the Site's functionality at the time of the acquisition of legal force of the privacy Policy are required to familiarize themselves with its current provisions. In this case, the Administration is obliged to send the current version of the privacy Policy to the persons mentioned in this paragraph of the privacy Policy. In this case, the email address specified by the User in the process of filling out the corresponding registration form of the Site is used.

 

1.12. Users, including those mentioned in clause 1.10., 1.11. those who have read and agree with the provisions of this privacy Policy, Express their full agreement with the terms of this privacy Policy and grant the Administration the right to use and process personal data about them for the purposes provided for by the functional purpose of the Site.

 

1.13. Not fulfilling the obligation provided for in paragraph 1.12. Privacy policy, the User is considered not to have accepted the terms of the privacy Policy. In this case, the User is prohibited from using the functionality of the Site, and the User is deprived of the possibility of using the functionality of the Site. In case of occurrence of the conditions provided for in this paragraph of the privacy Policy, the Administration undertakes to delete personal data about such person.

 

1.14. If you do not agree with the provisions of this document (in part or in whole), the person who has expressed such a will, has no right to use its Sites. At the same time, for such Party there are consequences provided by provisions of item 1.13. Privacy policy.

 

2. Principles of processing personal data of Site Users.

 

2.1. Personal data is processed legally, fairly and transparently by the Administration in relation to the User.

 

2.2. The processing of the User's personal data is carried out only in the case and only for the purposes for which this data is collected.

 

2.3. The User's personal data must correspond to, relate to, and be limited to the purpose of using the Site for which such data is processed.

 

2.4. The user's personal data used by the Administration is accurate and up-to-date. Outdated and inaccurate data are corrected or deleted by the Administration.

 

2.5. The administration conducts regular checks in order to clean the database in an orderly manner. The administration stores User information for a certain period of time, if this is due to justified commercial or legal purposes.

 

2.6. Personal data is processed by the Administration in such a way as to ensure proper protection of personal data, including protection against unauthorized or illegal processing, as well as against accidental loss, destruction or damage using appropriate technical or organizational measures.

 

3. How to use the information provided by users of the Site

 

3.1. To provide the User with services through the Site, the Administration collects two types of information: personal and non-personal information.

 

3.1.1. Personal information refers to information that allows you to know who the User is and that can be used to identify the user, communicate with Him or to determine his location (IP). If you refuse to provide your personal information, the User has access to most of the website.

 

3.1.2. The personal information that the User provides includes: first and last name, phone number, email address, and other contact information.

 

3.1.3. Personal information is collected by the Administration in the course of the following actions on the site:

 

using the account for payment;

implementation of the order of services performed through the activities of the Site;

subscription to advertising and newsletters.

3.1.4. The administration uses personal information of Users to provide services, send advertising and offers, as well as to improve the User experience on the Site.

 

3.1.5. Non-personal information contains information that does not identify a particular individual.

 

4. The purpose of collecting, processing and storing information provided by users of the Site

 

4.1. Processing of personal data about the User is carried out by the Administration only if the User has agreed to the processing of their personal data for one or more specific purposes.

 

4.2.  Processing of personal data about the User is carried out by the Administration in order to:

 

user identification within the framework of the relationship between the Administration and the User;

the Administration provides the User with a number of services offered on the Site;

conducting statistical and other research based on depersonalized data.

4.3. In the case where the Administration acts as a data Processor, data about third parties with whom the User interacts in the framework of its activities is collected by the Administration solely for the purpose of storage.

 

5. Rights of Users who provide their Personal data for processing

 

5.1. The user has the right to:

 

5.1.1. Get information from the Administration on request about:

 

          (a) for the purpose of processing User data by the Administration;

5.1.2. Get information from the Administration on request, defining the categories of personal data;

 

5.1.3. Require the controller to correct or delete personal data or restrict the processing of personal data in relation to the data subject or to object to such processing;

 

5.1.4. File a complaint with the relevant Supervisory authority that controls the processing of personal data;

 

5.1.5. the presence of automated decision-making, including the profiling referred to in articles 22 (1) and (4) of the GDPR, and, at least in these cases, meaningful information about the logic involved, as well as the significance and intended consequences of such processing for the data subject.

 

5.1.6. obtain from the controller, without undue delay, the correction of inaccurate personal data concerning the User.

 

5.1.7. for an indication of incomplete personal data, including through the provision of additional statements.

 

5.1.8. obtain from the controller the deletion of personal data concerning the User without undue delay, if there is at least one of the reasons:

 

- personal data is no longer required for the purposes for which it was collected or otherwise processed;

 

- the user does not agree with the provisions of the privacy Policy;

 

- there are no fundamental legal grounds for processing;

 

- personal data was illegally collected and (or) processed;

 

5.2. If the Administration has allowed a situation in which User data has become publicly available, the Administration is obliged to delete such User data, and taking into account the available opportunities and the cost of implementation must take reasonable steps, including technical measures, to inform the persons who process the personal data that the User wishes to delete, to remove any links to this data or to prevent their copying or replication.

 

6. Conditions for processing personal information provided by the User and its transfer to third parties

 

6.1. The administration takes all necessary measures to protect the user's personal data from unauthorized access, modification, disclosure or destruction.

 

6.2. The administration provides access to personal data about the User only to the circle of persons who need this information to ensure the functioning of the Site, and for the purpose of providing services to the User.

 

6.3. In order to provide services to the User, the Administration has the right to provide the User's personal information to third parties in order to provide the ordered services. In this case, the information is transmitted confidentially, and in accordance with all obligations to ensure the security of personal information.

 

6.4. The administration has the right to use the information provided by the User, including personal data, in order to ensure compliance with the requirements of the current legislation of the Russian Federation (as well as to prevent and / or suppress illegal and / or illegal actions of Users). Disclosure of User-provided information can be made only in accordance with the current legislation of the Russian Federation by a court order, request by law enforcement authorities, and in other stipulated by the legislation the Russian Federation cases.

 

6.5. The administration applies the necessary measures, from a commercial point of view, to prevent the collection, modification or destruction by third parties of information received at the disposal of the Administration on the Site.

 

6.6. Measures specified in paragraph 6.5. this includes monitoring the network flow to identify unauthorized attempts to download or modify information, and, under certain circumstances, encoding confidential information using secure connection Protocol (SSL) or other similar technologies. The site also provides controls to prevent any illegal activities, or activities that may expose the Administration to legal liability or cause damage to it.

 

6.7. The administration undertakes to ensure the security of the Site, as well as the continuous observance of its legality in such a way that the services provided through the Site remain accessible to all Users.

 

6.8. Despite the fact that the Administration takes all necessary, from a commercial point of view, measures to prevent the collection of unauthorized third parties, personal information of Users transmitted to the Administration through the Site, illegal interception or possession of information by third parties is still possible.

 

6.9. In case of leakage/hacking/compromise of personal data, the Administration undertakes to bring this fact to the attention of the relevant authorities, no later than 72 hours after the Administration became aware of such leakage/hacking/compromise.

 

7. Terms of Use

 

7.1.The user, when using the Site, confirms that:

 

7.1.1. he has all the necessary rights that allow him to acquire civil rights for himself and to exercise them independently, as well as the ability to create civil duties for himself by his actions, to perform them independently and to bear responsibility if they are not fulfilled;

 

7.1.2. indicates reliable information about yourself in the amount necessary to use the services of the Site. Mandatory fields for further provision of the Site's services are marked in a special way-the symbol"*", all other information is provided by the user at his own discretion.

 

7.1.3. you have read the terms of this privacy Policy, agree to it, and accept the rights and obligations set forth in it. Familiarization with the terms of this privacy Policy and putting a tick under the link to this Policy is a written consent of the User to the collection, storage, processing and transfer to third parties of personal data provided by the User.

 

7.1.4. The administration does not verify the accuracy of the information received (collected) about Users, except for cases when such verification is necessary for the purpose of fulfilling obligations to the User, as well as other cases not provided for by the provisions of the privacy Policy, but established by the current legislation of the Russian Federation.

 

7.1.5. using the functionality of the Site, agrees to receive periodic e-mail messages about updates to the services provided through the Site.

 

7.2. The user has the right to receive personal data about him, which the User has provided to the administration, and also has the right to transfer this data to other persons, without interference from the Administration, which was provided with such personal data.

 

7.3. The user has the right to object to certain types of processing of his personal data-direct marketing, processing for the purpose of protecting legitimate interests or performing any task in the public interest / exercise of power, as well as data processing for research or statistical purposes.

 

7.4. The administration has the right to provide links to third-party websites and materials.These links to third-party websites and materials are provided solely for the purpose of providing information.

 

8. For the purposes of this privacy Policy, "personal information about the User" means:

 

8.1. Data provided by the User independently in the course of using the Site, including, but not limited to: first name, last name, contact phone number and / or email address, ip address, MAC address, other.

 

8.2. Data automatically transmitted to the Site during its use by the software installed on the User's device, including the IP address, information from the cookie, information about the user's browser (or other program that is used to access the Site), access time, the address of the requested page.

 

8.3. The administration uses non-personal information through the use of cookies non-personal information through the use of cookies or through the collection of information exchange flow produced in order to optimize the use of the Site. the date and time of the visit to this website, etc. Examples of the flow of information exchange include:

 

the name of the domain or URL address from which the user enters the Internet;

Internet Protocol (IP) address);

type of web browser used;

date and time of visit to this website, etc.

8.4. Other information about the User, the collection and / or provision of which is determined by the terms of use of the Site.

 

9. Changing and deleting personal data

 

9.1.The user can at any time change (update, Supplement) the personal information provided by them or part of it, as well as the parameters of its confidentiality, by sending this information to the Administration's e-mail box.

 

9.2. The user may at any time delete the personal information provided by him or part of it, in order to avoid its distribution or transfer to third parties.

 

9.3. The administration has the right to delete personal data about the User, if they are no longer needed for the purposes for which they were collected, as well as, in the absence of other reasons for their storage.

 

10. Changes to the privacy Policy.

           (b) persons to whom personal data has been or will be disclosed, in particular recipients in countries outside the European Union or international organizations;

10.1. The administration has the right to make changes to this privacy Policy. When making changes to the current version, the date of the last update is indicated. The new version of the privacy Policy comes into force from the moment of its publication on the Site, unless otherwise provided by the new version of the privacy Policy. The current version of the privacy Policy is available at: http://spilna.com/conditions

 

10.2. This privacy Policy and the relationship between the User and the Administration arising in connection with the application of the privacy Policy shall be subject to the application of the law of the Russian Federation.

 

11. Contact details

 

11.1. All suggestions or questions about this privacy Policy should be reported to the Administration at the appropriate email address: admin@spilna.com

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