AGREEMENT FOR THE PROCESSING OF PERSONAL DATA AND PRIVACY POLICY

 

Last updated October 12, 2020

This confidentiality document (Privacy Policy, Agreement) describes how IE Savateev Dmitry Vladimirovich and / or his affiliates (hereinafter - the Company) work with personal information and protect your confidentiality. The company acts as an operator (hereinafter referred to as the operator) of your data, which is described in more detail in the section "Organizations collecting personal data" of this document "and the processes of processing and protecting data on the sites https://mipif.online/, mipif.online.

This Agreement can be amended or supplemented at the discretion of the Company and the Site administration at any time by sending you a special notification of this by e-mail or otherwise. However, we encourage visitors and users of our sites to regularly review the Privacy Policy.

All private (personal) information that we receive and store, which is defined as any information that identifies a person or determines his location, is subject to the terms of this Privacy Policy in its current version. Personal data means any information relating to a specific or determined on the basis of such information to an individual. In this regard, the Company has done everything possible to ensure that you have easy and unrestricted access to information about the privacy policy and at any time could resolve the issue of compliance with it and the use of your data. The policy regarding the processing of personal data by the Company is presented on all pages of the site in the footer and is available at the link https://mipif.online/privacy-policy/

To update your personal information and settings, see the section “Accessing Personal Information, Updating, Deleting Information, and Changing Your Privacy Settings”.

In accordance with the Regulation of the European Parliament and of the Council of the European Union 2016/679 on the protection of individuals to the processing of personal data (hereinafter GDPR), the Company undertakes to fulfill its obligation to keep confidentiality of personal data, to follow EU regulations and legislation on the receipt, processing and protection of data. For these purposes, the Company will take the necessary measures to secure the received personal data and protect them from unauthorized access.

 

Privacy protection basics

The company supports the EU regulation of the European Parliament and the Council of the European Union 2016/679 on the protection of individuals with respect to the processing of personal data (GDPR). The company makes every effort to handle all personal data received from member states of the European Union (EU) in accordance with the applicable principles of the Privacy Shield Framework. To learn more about the Privacy Shield Framework, we recommend that you familiarize yourself with the rules and regulations for data protection, data storage and confidentiality, which are valid inside and outside the EU, drawn up by the European Commission https://ec.europa.eu/info/law/law-topic/data-protection_en.

The Company is responsible for the processing of the personal data received in accordance with the GDPR and transfers the corresponding obligations to any third-party agents acting on its behalf. The company complies with the principles of protection of confidentiality with respect to any further transfer of personal data from the EU, including with regard to the further transfer of obligations.

The subjects whose personal data is processed in the Company with or without automation tools are:

·   Users and subscribers of the Company's website on the Internet;

·   Company employees or persons who have had an employment relationship with the Company, as well as their family members;

·   Persons who have a civil law contractual relationship with the Company, or who are at the stage of pre-contractual or completed relationships of a similar nature;

·   Partners and members of the Company;

·   Contractors of the Company, represented by individual entrepreneurs, their employees; founders, managers, representatives (persons acting on the basis of powers of attorney) and employees of legal entities that have or have had contractual relations with the Company, or who wish to conclude contracts with the Operator;

·  Visitors to the offices of the Company;

·   Other persons whose personal data processing is necessary for the Company to achieve the goals specified in this Policy.

When we say "you," "your," or "yours," we mean referring to the subject.

In relation to personal data received or transmitted in accordance with the GDPR, the Company is subject to the enforcement of the European Commission. In certain situations, the Company may be required to disclose personal data of a legitimate request received from government authorities, including to meet national security and law enforcement requirements.

If you have doubts about confidentiality or the use of data that we were not able to satisfactorily resolve, you can contact the employee of the company authorized to be responsible for compliance with the Privacy and Data Protection Policy, information about which is presented in the section "Authorized person of the company in charge of for data processing ". When the procedure for resolving disputes with an authorized person of the Company has been exhausted, you have the right to resort to binding arbitration or contact the relevant authorities for the protection of user data. Official information on EU national data protection authorities can be found here: https://ec.europa.eu/commission/sites/beta-political/files/national-data-protection-authorities-jan_2018_en.pdf.


Organizations collecting personal data

This Agreement and the Privacy Policy are issued on behalf of the individual entrepreneur Dmitry Vladimirovich Savateev and / or its affiliates. When we say “Company”, “operator of personal data”, “we”, “our”, “us” or “, as well as “MIPIF” we mean the respective organization responsible for processing your data. Which Company acts as the operator of your data is determined in the relevant terms of service or this Agreement. Personal data on this website is obtained by the Company:

IE Savateev Dmitry Vladimirovich

INN: 780531929224

OGRN: 311784715700457

Address: 198 262 St. Petersburg st. Leni Golikov 36, 8

Bank: Branch "St. Petersburg JSC" Alfa-Bank"

Bank account: 40802810332030000117

Correspondent account: 30101810600000000786

BIK: 044030786

Email: info@mipif.online

Tel.: 8 (812) 766 43 44.

 

Authorized person of the company in charge of data processing

The Company has appointed an authorized person (hereinafter DPO - data protection officer) who is responsible for compliance with the Privacy Policy, personal data protection, communication on issues related to this privacy document. Dmitry Vladimirovich Savateev is the authorized person responsible for compliance with the Privacy Policy, control and management of personal data, systematic monitoring of the data of individual users and persons responsible for compliance with the protection rules.

Dmitry Savateev

Email: info@mipif.online

If you have any questions or concerns about this Agreement and the Privacy Policy, how we manage your personal data, or if you have any other concerns about your personal information, be sure to contact our personal data protection officer.


Categories of collection of personal data and processed information

You can perform some operations on the website without providing personal information.

 But, when you register, leave data for using the Company's website and other products or services, and become a subscriber to the site, so that we can provide you services, we may receive the following personal information from you:

·  Contact details (your name, phone number, email address);

Depending on the operations performed, part of the requested information is required to be provided, and part is provided at your discretion. If you do not provide the required information, you will not be able to perform the corresponding operations and interact with the site to the fullest.

Like most websites of organizations, the Company and its independent ancillary operators may, when you use the website, receive certain technical and routing information about your computer to make it easier for you to use the website and its services. For example, we may record environment variables such as browser type, operating system, processor speed, and your computer's IP address. We use these environment variables to track your use of the site and its services and to make them more user-friendly. The company also uses these environment variables to track traffic to the site. We may from time to time combine this data with your personal information in order to better understand the needs of site visitors.

In order to reduce the number of errors in our database, authenticate users and prevent misuse of the system, we may from time to time supplement the personal information you provide with information from third-party public sources. We may supplement information we receive directly from you with information stored in third-party databases, such as demographics or company data, in order to increase the likelihood that any marketing messages we send you will be truly useful and interesting to you. A list of third party ancillary operators that we may call upon is provided in this document.

When you download and use our mobile applications or services, we automatically receive information about the type of device you are using, as well as the version of the operating system.

The company may collect and use information about the geographic location of your computer or mobile device. The purpose of collecting this data is to provide you with information about services in your area that might interest you and to improve the products and services offered there.


Purposes of receiving and storing data

All personal data received by the Company is necessary so that we understand better your needs when interacting with the site, improve technical characteristics and marketing activities for your convenient use of the site.

We collect personal information and use environment variables to track your use of the site and its services, and to improve your user experience. The company also uses these environment variables to track traffic to the site. We may from time to time combine this data with your personal information in order to understand better the needs of site visitors.


How your personal information is used

The company collects your personal information in order to provide services to you, to comply with our legal obligations and to improve our products and services. We do not sell, rent, or provide personally identifiable information to third parties in any other way other than that described in this Privacy Policy. The company can use this information for the following purposes:

·   Responding to requests to the Company from users when interacting with the website;

·   Sending you requested information about products or services;

·   Response to inquiries and complaints sent to the support service;

·   Informing you about special offers and services of the Company and selected third parties;

·   Manage advertising campaigns in which you participate by accepting this Agreement;

·   Investigating, warning or taking action in relation to illegal actions and / or violations of the terms of service;

·   Carrying out research and development in the field of products / services to improve our site, as well as offers and services;

·   Satisfying your personal requests and preparing services and offers individually for you.

The information collected through cookies, logs, transparent image data and / or third-party resources is used to create a database of your preferences. We link your personally identifiable information and / or membership history to the information in this database to prepare customized advertising offers, improve site content and identify your interests.

In some cases, at the official request of the authorized bodies, the Company is obliged to disclose your personal information in order to comply with national security requirements or ensure law and order.

In situations where it is required by law (for example, for the execution of a subpoena, order, ruling or court decision against the Company), and also when we believe that disclosure of information is necessary to protect our rights, in order to avoid legal proceedings, to ensure your safety or the safety of others, for fraud investigations and / or at the request of government agencies. We may also disclose information about you if such disclosure is necessary in the interests of national security, law enforcement or other matters of national importance.

Sharing personal information with other organizations, service providers and agents

The Company employs certain ancillary operators (which include organizations and third parties, as listed below), subcontractors and content delivery networks that assist in maintaining the site and providing the services described in the service agreement.


About auxiliary operators

An auxiliary operator is a third-party organization (including IE Savateev Dmitry Vladimirovich and affiliated companies) engaged by the Company for data processing, which has or may have access to information of customers or users (including those containing personal data) or the ability to process such information. The Company is committed to employing a commercially reasonable due diligence process to assess the security and privacy practices employed by the proposed ancillary operators who will or may have access to, or the ability to process, Company data.

The company requires the auxiliary operators with whom it works to accept certain terms and conditions governing the use of information and personal data of subjects, including, without limitation, binding it:

·  Process personal data in accordance with the Regulation of the European Parliament and the Council of the European Union 2016/679 on the protection of individuals with respect to the processing of personal data (GDPR);

·  Engage trustworthy employees who comply with contractual confidentiality and data protection obligations to the extent necessary in accordance with applicable data protection laws;

·  Regularly conduct trainings on security and data protection for employees who are provided with access to personal data;

·  Implement and apply appropriate technical and organizational measures to ensure the security, integrity and confidentiality of information and personal data of the customer;

·  Conduct an annual review of compliance with applicable data protection laws, or authorize the Company to audit such compliance;

·  Promptly inform the Company about any actual or possible security incident or data breach;

·   Provide all reasonable assistance to the Company when dealing with requests from personal data operators, data subjects or bodies supervising compliance with legislation on the protection of personal data, if any.

The information provided here is intended solely to demonstrate the process of the Company's interaction with auxiliary operators, as well as to provide an up-to-date list of third-party auxiliary operators engaged by the Company on the effective date of this Privacy Policy (that is, those that the Company may engage to provide services and ensure their operation). If you have any questions about this notice or the involvement of these subsidiary operators by the Company, please contact us at info@mipif.online.

 A list of such third-party auxiliary operators:

1. Google.Analytics. You can find detailed information on using the system here: http://www.google.com/analytics/learn/privacy.html

2. Yandex.Metrica. You can find detailed information on using the system here: https://yandex.ru/legal/confidential/

3. Pixel Facebook. You can find detailed information on using the system here: https://www.facebook.com/privacy/explanation

4. VK pixel app. You can find detailed information on using the system here: https://vk.com/page-19542789_53869861

5. RedConnect. You can find detailed information on using the system here: https://web.redhelper.ru/nx/eula?c=rhlp&site=https://redhelper.ru

6. Captcha from Google (reCAPTCHA).

7. Subscription to the Telegram channel. You can find detailed information on using the system here: https://tlgrm.ru/privacy

8. Sendpulse https://sendpulse.com/legal/pp


Transfer of personal data to another country or state

The company does not transfer the received personal data on the territory of other states. In the event of a transfer, the Company is obliged to ensure that the foreign state, to whose territory it is supposed to transfer personal data, provides adequate protection of the rights of subjects of personal data, prior to the start of such transfer.

Cross-border transfer of personal data on the territory of foreign states that do not provide adequate protection of the rights of subjects of personal data can be carried out in the following cases:

·  The presence of consent in writing (including using the hardware of the company's X website on the Internet) of the subject of personal data for the cross-border transfer of his personal data;

·  Execution of a contract to which the subject of personal data is a party.

When posting data in countries that have not been approved by the EU authorities, the Company will take legal measures enshrined in the contract.


Access to personal data, updating, deleting information and changing privacy settings

At your request, directed to an authorized person or to the company's address, we will provide you with information about whether we store or process any of your personal information in the interests of third parties. To request this information, please contact us at info@mipif.online.

You have the right to access your personal information and privacy settings at any time in order to change or delete them. This also can be done by sending us an email request to info@mipif.online or an authorized street. We will respond promptly to your request within a reasonable period. Within 30 days, we will change, update or delete information about you with all personal data.

You can also ask to transfer personal data to you or to another organization by sending a request to an authorized DPO employee at info@mipif.online, who will transfer personal data to you and evaluate the technical possibility of transferring the data of the subject to another organization. 


Storage and protection of personal data

The personal information that you provide in connection with your use of the site is protected in several ways.

·  Your personal information is located on secure servers, which can only be accessed with a password by a narrow circle of employees of the Company and affiliated organizations.

·  At the time of transfer of personal data through the website, the information is encrypted.

We do our best to protect the personal information sent to us, both during transmission and after receipt. However, none of the methods of transmitting information over the Internet, as well as electronic storage of information, is absolutely reliable. In addition, although we take into account the confidential nature of the personal information we receive, process and store, as well as the current state of technology, in order to choose adequate measures to protect your personal information, we cannot guarantee its absolute security.

 If you have any questions regarding security on our website, please contact us at info@mipif.online or an authorized DPO officer at info@mipif.online.

Ensuring the security of personal data

The security of personal data processed by the Company is ensured by the implementation of legal, organizational and technical measures necessary to meet the requirements of federal legislation in the field of personal data protection.

To prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:

·  Appointment of officials responsible for organizing the processing and protection of personal data;

·  Limitation of the composition of persons admitted to the processing of personal data;

·  Familiarization of subjects with the requirements of EU legislation and regulatory documents of the Operator on the processing and protection of personal data;

·  Organization of accounting, storage and circulation of media containing information with personal data;

·  Identification of threats to the security of personal data during their processing, the formation of threat models on their basis;

·  Development of a personal data protection system based on the threat model;

·  Checking the readiness and effectiveness of the use of information security tools;

·  Differentiation of user access to information resources, software, and hardware for information processing;

·  Registration and accounting of actions of users of information systems of personal data;

·  Use of anti-virus tools and means of restoring the personal data protection system;

·  Use, if necessary, means of firewalling, intrusion detection, security analysis and means of cryptographic protection of information;

·  Organization of access control to the territory of the Operator, protection of premises with technical means for processing personal data.


Data storage periods

We will retain your information as long as your account is active, as long as the information is needed to provide you services, or as long as it is necessary to fulfill our legal obligations. If you wish to delete your account or request that your information no longer be used to provide services to you, you can contact the authorized person at info@mipif.online or the company's address. We will respond to your request within 30 days. We will store and use your information for as long as it is necessary to comply with our legal obligations, resolve disputes and comply with agreements entered into by us.

Refusal from marketing activities, receiving updates newsletters and / or information messages

You can opt out of receiving updates by e-mail and newsletters from the Company and / or e-mails from partners by making the appropriate choice, or by contacting the authorized person in charge of data storage and processing (DPO) by e-mail info @ mipif.com. You can also opt out of receiving such messages during the registration process. In this case, you will receive notifications from the Company in the event of changes in the Terms of Service or the Terms for the provision of information for site users. In addition, in any case, we will send you messages regarding the provision of services, including a registration letter. Usually, you cannot opt out of receiving such messages, which are not advertising. If you do not want to receive them, you can delete your personal data and cancel the receipt, contact the DPO responsible person with a request to delete the data at info@mipif.online, or not use the site. If you do not agree to comply with all or some of the provisions of this agreement, do not use the site and leave it immediately.


Changes to privacy policy

The Company reserves the right to make changes to the Privacy Policy at any time at its sole discretion and undertakes to specifically notify you of material changes by email or otherwise. Any changes to the Privacy Policy can always be found on the pages of the site or by contacting the responsible person of the DPO - Dmitry Savateev by e-mail info@mipif.online, requesting information about the changes. We do our best to ensure that information about changes to the Privacy Policy is available to you at any time. If, as a result of such changes, you want to change the procedure for the permitted use of your personal information by the Company, you can do so by following the procedure described in the Updating personal information and privacy settings section or by contacting us at info@mipif.online or the DPO responsible officer.

 After posting changes and updates to the Privacy Policy on the site, you are considered aware of any significant changes in the Privacy Policy and they begin to apply to you with the following exception: if at the time you provide personal information to the Company, you are given the opportunity (as at the moment) to restrict the use of such information for communication with you from the Company or third parties. The Company has no right to change your preferences in this regard without your explicit consent. However, if the Company ceases to exist as a legal entity, transfers assets, control and management of them to another company, a merger, takeover or takeover by another company occurs, the Company may, without your consent, provide such company with information about users and customers related to that part of the commercial or a non-profit activity that has been transferred to another company. In this case, the Company is obliged to place a notice of such sale of assets, takeover or merger on this website.


Cookie and Tracking Technologies

When you search the Internet, the site may automatically collect information such as data about your Internet service provider, browser type and version, operating system and device type, average time spent on our site (s), pages viewed, information, to accessed, the Internet Protocol (IP) address used to connect your computer to the Internet, and other relevant statistics. This information is called web analytics or visit data.

We may combine this automatic log information with other information we collect about you. We do this in order to improve the quality of the services offered to you, improve marketing strategy and analytics, and ensure good functionality of the site.

The company and our affiliates, analytics and service providers use technologies such as cookies, beacons, tags and scripts to ensure the functionality of the site. These technologies are used to analyze trends, administer the site, track user movements around the site, and collect demographic information about our users in general. We may receive reports based on the use of these technologies by these companies, both on an individual basis and in the form of aggregate data.

·  A cookie is a small, unique text file that a website sends to your computer when you visit this website. We may use session cookies, which are automatically deleted when the user closes their browser, and / or persistent cookies, which remain on the user's computer until manually deleted. Most web browsers can either warn you about the use of cookies or refuse to accept cookies entirely. If you do not want us to enable cookies in your browser, you can set your browser to refuse cookies or to notify you when a website tries to install cookies on your computer. Refusing cookies may affect your ability to use this site.

·  We collaborate with a third party either to display ads on our website or to manage the display of our ads on other sites. The third party we work with may use technologies such as cookies to collect information about your activities on this site and other sites in order to serve you ads based on your browsing activities and your interests. If you are located in the European Union and do not want this information to be used to offer you interest-based advertising, you can opt-out by clicking here. You can also control the display of ads by deleting cookies in the browser you are using. Please understand that this does not mean that you opt out of receiving advertising. You will continue to receive regular ads.


Web beacon

A web beacon is a small graphic file on a web page that can be used to retrieve certain information from your computer, such as the IP address, the duration of the study of the content of the web page, the type of browser, and the presence of cookies, previously created by the same server.

The company uses these web beacons in strict accordance with applicable law. The company or auxiliary operators - service providers may use web beacons to monitor the performance of third-party websites that provide us with various services, including marketing services, or to collect aggregated statistics about online visitors to the site and manage cookies.

You have the option to disable certain web beacons by blocking the cookies associated with them. In this case, the web beacon will be able to register an anonymous visit from your IP address, but the information in the cookie will not be recorded.

If you subscribe to our newsletters or other materials, we may monitor the actions of recipients, for example, through embedded links within messages, we may collect information about the number of recipients who opened a particular message. The collection of this information is carried out in order to assess which sections of the site are of the greatest interest to users.

Links to Third Party Sites

Our site contains links to other websites whose privacy policies may differ from the Company's privacy policies. If you provide personal information on any of these sites, your information will be processed in accordance with the privacy policy of this site. We recommend that you carefully read the privacy policy on each site you visit.


Social media widgets

Our website may include social media features and widgets such as the Share button and interactive mini programs that are launched when you interact with the site. These features can receive your IP address, track which page you visit on our site, and set cookies to work properly. Functions and widgets for social networks can be performed either directly on our website or on third-party resources. Your interactions with these features are governed by the privacy policy of the company providing them.


Referral Program Email Addresses

If you would like to use our referral program to inform your friend about our site or an individual page of the site, you need to provide his name and email address to the DPO responsible. We will send him a one-time letter inviting him to visit our website. The company retains this information for the sole purpose of sending such a letter and tracking the effectiveness of our referral program.

Your friend may contact the DPO in charge at info@mipif.online to request the removal of this information from our database.


Receiving and processing personal data from children - subjects under the age of 21

We do not aim to solicit or receive personal information from anyone under the age of 18. If you are under 18 years old, do not enter information on this site and do not use our services. If you believe that your child under the age of 18 has entered personal data, please inform the DPO responsible at info@mipif.online so that we delete the data and the child's account.

If there are any suspicions related to the minority of a user of the website or a client of the company, an employee of the company interacting with the subject or an authorized DPO employee has the right to request the consent of the parent or guardian to process the personal child.


Privacy Complaints

Individuals living in certain countries, including countries in the European Economic Area, have certain legal rights with respect to their personal data. You may have the right to request access to information and to request that information be updated, removed or corrected, subject to any exceptions provided by law.

To the extent that the Company that processes your personal data is subject to the EU's General Data Protection Regulation, the Company relies on its legitimate interests described above to process your data. When the Company processes certain personal data for the implementation of its own targeted marketing activities, you have the right at any time to object to the use of your personal information by the Company for these purposes.

The company takes user privacy issues seriously. If you believe that the Company is not complying with this Privacy Policy with respect to your personal information, you can contact the DPO's data protection officer at info@mipif.online. In your letter, describe in as much detail as possible the cases of the Company's alleged violation of the Privacy Policy. We will review your complaint as soon as possible. If you have not received confirmation of receipt of your complaint within 30 days of sending the letter, or your complaint is not satisfactorily resolved, you can always contact a third-party information and privacy dispute resolution partner or file a complaint with the local authorities responsible for resolving data protection disputes.

Information on updates to data protection laws and regulations and data protection authorities: https://ec.europa.eu/commission/priorities/justice-and-fundamental-rights/data-protection/2018-reform-eu-data-protection-rules_en

If you have any questions about this Privacy Policy, working methods or your interaction with the website, you can contact our authorized person for the protection of personal data Dmitry Vladimirovich Savateev at info@mipif.online.


Company details

IE Savateev Dmitry Vladimirovich

INN: 780531929224

OGRN: 311784715700457

Address: 198 262 St. Petersburg st. Leni Golikov house 36 sq. 8

Bank: Branch "St. Petersburg JSC" Alfa-Bank"

Bank account: 40802810332030000117

Correspondent account: 30101810600000000786

BIK: 044030786

Email: info@mipif.online

Tel.: 8 (812) 766 43 44.


Link to Regulation 016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (General Data Protection Regulation): http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2016.119.01.0001.01.ENG&toc=OJ%3AL%3A2016%3A119%3ATOC

Information on updates to data protection laws and regulations and data protection authorities: https://ec.europa.eu/commission/priorities/justice-and-fundamental-rights/data-protection/2018-reform-eu-data-protection-rules_en