Personal Data Processing Policy
This Personal Data Processing Policy (hereinafter referred to as the "Policy") has been developed in accordance with the requirements of Clause 2 of Part 1, Article 18.1 of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter referred to as the "Personal Data Law") in order to ensure the protection of the rights and freedoms of a human being and citizen when processing his or her personal data. This Policy is developed in accordance with the requirements of the Constitution, legislation, and other regulations of the Russian Federation in the field of personal data.
This Policy applies to all personal data processed by SPARTA LLC (hereinafter referred to as the "Operator") in connection with providing access to the GetUNIQ service.
If a User/Party declines the processing of their personal data according to this Policy, that User/Party will not be allowed access to GetUNIQ.
The User's use of GetUNIQ confirms the User's consent to this Policy.
I. General provisions
1.1. The Policy applies to relationships in the field of personal data processing that arise for the Operator both before and after the approval of this Policy.
1.2. Personal data is any information relating to a directly or indirectly identified or identifiable individual (personal data subject).
De-identification of personal data is the actions that result in being unable, without the use of additional information, to determine that personal data belongs to a specific personal data subject.
1.3. The Operator does not verify the accuracy of the personal data provided by the User and cannot assess his or her legal capacity. However, the Operator and the User assume that the User provides accurate and sufficient information and keeps this information up to date.
1.4. If the Operator receives a notification from the User about the withdrawal of consent to process personal data, the Operator shall terminate the processing of the User's personal data within a period not exceeding 10 (ten) business days from the date of receipt of such notification. Such notifications are sent to the email address data-support@getuniq.me, as well as by written request to the address 2 Novodmitrovskaya St. 2, bldg. 1, floor 6, Moscow, Russian Federation, 127015.
II. Objectives of processing personal data
2.1. Providing and improving the services offered to the User through the use of GetUNIQ, identifying the User, creating an account
2.2. Communicating and interacting with the User, including sending notifications, requests, and processing Users' requests
2.3. Analyzing the volume of services rendered through the use of GetUNIQ
2.4. Assessing the quality of services provided through the use of GetUNIQ
2.5. Sending information via telecommunications networks, including by means of telephone, facsimile, mobile radiotelephone communication (email, telephone, etc.) for the purpose of sending promotional and informational messages containing information about the services, goods, and works of the Operator and its partner organizations.
III. Legal grounds for processing personal data
3.1. The legal basis for processing personal data is a set of regulations in compliance with and in accordance with which the Operator processes personal data, including:
– Federal laws and other regulations in the field of personal data protection
– Users' consent to the processing of their personal data and to the processing of personal data permitted for distribution
– Other regulations governing relations related to the Operator's activities.
IV. Conditions for the collection of personal data and the procedure for processing it
4.1. The Operator provides the User access to his or her personal data by providing a username and password
4.2. The Operator processes personal data only with the User's consent, as well as in cases provided for by the legislation of the Russian Federation
4.3. The Operator ensures the legality of the purposes for and methods of processing personal data, maintaining the integrity of its actions in processing
4.4. The Operator processes only the personal data that corresponds to the purpose for processing it
4.5. The Operator does not combine personal data with other data of the Operator, including data from other operators
4.6. The Operator carries out automated processing of personal data (i.e., processing of personal data using computing tools)
4.7. The Operator takes all necessary measures to protect Users' personal data. The Operator provides personal data subjects with recommendations for protecting personal data on equipment owned by the User.
4.8. The processing of personal data by the Operator includes, among other things, collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), de-identification, blocking, deletion, and destruction. The processing of personal data is any action (operation) or set of actions (operations) with personal data performed with or without the use of automation tools.
4.9. The Operator stores personal data in a form that allows the personal data subject to be identified no longer than required for the purposes of processing personal data unless the storage period of personal data is established by federal law or contract.
4.10. When collecting personal data, including via the Internet, the Operator ensures the recording, systematization, accumulation, storage, clarification (updating, modification), and extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except in cases specified in the Personal Data Law.
V. Personal data that can be processed by the Operator:
- Last name, first name, middle name or patronymic
- Contact information (including phone number and email address)
- IP address
- Internet browser
- Referral link
- Cookies
- Location data
- Other personal data provided by the User necessary to interact with GetUNIQ within the access granted).
VI. Disclosure and transfer of Users' personal data
6.1. Disclosure of personal data to third parties and distribution of personal data without the User's consent are not allowed unless otherwise provided by federal law.
6.2. The transfer of personal data to law enforcement and investigation agencies, the Federal Tax Service, and other authorized executive authorities and organizations is carried out in accordance with the requirements of the legislation of the Russian Federation.
6.3. The Operator takes the necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, distribution, and other unauthorized actions, including (but not limited to):
- Assessing threats to the security of personal data when processing it
- Adopting local regulations and other documents regulating relations in the field of processing and protecting personal data
- Creating the necessary conditions for working with personal data
- Organizing the accounting of documents containing personal data
- Organizing work with information systems in which personal data is processed
- Storing personal data under conditions that ensure their safety and prevent unauthorized access.
VII. Rights and obligations of the Operator
7.1. The Operator guarantees good faith and transparency in the use of the User's personal data.
7.2. If the User requests access to his or her personal data, the Operator is obliged to provide such access to the User within a reasonable period of time.
7.3. If the User withdraws his or her consent to process their personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law.
7.4. If the User discovers an error in his or her personal data, he or she must immediately contact the Operator. The Operator is obliged to correct the error as soon as possible.
7.5. At the User's request, the Operator may delete some personal data without affecting the provision of services to the User, but the Operator also has the right to refuse to delete part of the User's personal data. In this case, the User may refuse to provide services.
7.6. The Operator has the right to request the User to clarify his or her personal data. The Operator must indicate the purpose of the correction.
7.7. The Operator has the right to independently determine the composition and list of necessary and sufficient measures to ensure the fulfillment of the obligations established by the Personal Data Law and the regulations adopted in accordance therewith unless otherwise provided by the Personal Data Law or other federal laws.
7.8. Upon achieving the objectives of personal data processing, as well as in the event of the User's withdrawal of consent to processing personal data, personal data shall be destroyed by the Operator if:
- Not otherwise provided for by the contract, the party to which, the beneficiary or guarantor, which is the User of personal data
- The Operator does not have the right to process without the consent of the personal data subject on the grounds provided by the Personal Data Law or other federal laws
- Not otherwise provided for by another agreement between the Operator and the User of personal data.
VIII. Final provisions
8.1. This Policy is subject to change and supplementation in the event of new legislative acts and special regulatory acts on the processing and protection of personal data, as well as at the Operator's discretion, by posting the updated version of the Policy on the website at https://getuniq.me/privacy-policy.
8.2. The term for processing personal data processed by the Operator is determined by its organizational and management documents in accordance with the provisions of the Personal Data Law.
8.3. This Policy reflects the Operator's commitment to complying with the law and protecting Users from any unauthorized interference in their personal information when using the Operator's service, including the User's intention to become the Operator's client and the deletion, maintenance, and systematization of the User's personal data.
8.4. This Policy comes into effect from the date of its publication on the website https://getuniq.me/privacy-policy — getuniq.me.
8.5. The User has the right to contact the Operator regarding the processing of his or her personal data by email at data-support@getuniq.me.