Russian Federation, Moscow
Version of 06.07.2021
Commencement date: 09.07.2021
This Privacy and Personal Data Protection Statement (hereinafter – Privacy Policy) determines the procedure of processing and protection of personal data of physical persons (hereinafter – Users) collected by the Operator when the User accesses the website located at the address https://apexcom.net (hereinafter – Website) and uses the services and programs provided by the Operator.
1. GENERAL PROVISIONS
1.1. The personal data operator is the Limited Liability Company ‘APEXCOM’
(OGRN 1217700163746, INN 7726475790, KPP 772601001117105) (hereinafter – Operator).
1.2. The User’s personal data are processed for the purposes indicated in 2.2. Personal data processing can be performed by any lawful means, including the use of information systems of personal data, manually or automatically (mixed personal data processing). Users’ personal data processing is performed in accordance with the Federal Law of 27.07.2006 № 152-FZ ‘On Personal Data’.
1.3. Consent to personal data processing comes into effect from the moment of its submission to the Operator and until the moment of the Operator’s loss of the status of an individual entrepreneur.
1.4. The main terms used in the Privacy Policy are as follows:
1.4.1 ‘personal data’ means the data relating to the User that the User furnishes in the process of using the Website, including the User’s personal data (the data whose transfer is mandatory for the provision of the services is specifically marked; other information is provided by the User at their own discretion) and the data that are automatically transferred to the Website’s services in the process of their use through the software installed on the User’s device, including IP-address, cookie files, information relating to the User’s browser type (or other software for accessing the services), technical characteristics of the User’s hardware and software, the last accessed date and time, the requested web page address, and other such information or other User information whose processing is provided for under this Privacy Policy;
1.4.2. “processing of personal data” means any action (operation) or a set of actions (operations) performed on personal data realized by automated means or manually; personal data processing includes the gathering, recording, systematizing, accumulating, storing, updating (renewing and altering), retrieving, using, transmitting (disseminating, providing and accessing), depersonalizing, blocking, deleting and destroying personal data.
1.4.3. “automated personal data processing” means the processing of personal data by means of computer equipment;
1.4.4. “dissemination of personal data” means the actions aimed at disclosing personal data to an unlimited group of persons;
1.4.5. “provision of personal data” means actions aimed at disclosing personal data to a certain person or a certain group of persons;
1.4.6. “blocking of personal data” means temporary termination of personal data processing (except for cases when processing is needed to ensure that the personal data are accurate);
1.4.7. “depersonalization of personal data” means actions resulting in the impossibility of attributing personal data to a particular data subject without the use of additional information;
1.4.8. “destruction of personal data” means actions resulting in the impossibility to recover the content of personal data in the personal data information system and/or that leads to the physical destruction of the storage media on which the personal data are stored.
1.5. The use of the services offered by the Website shall constitute an unconditional assent to the terms and conditions of this Privacy Policy; if the User does not unconditionally agree to all of these terms and conditions, then he or she should refrain from using this Website and its services.
1.6. The Website Administration does not verify the accuracy of the personal information submitted by the User and does not exercise control over the User’s legal capacity. The Website Administration, however, assumes that the User provides reliable and sufficient personal information on the questions included in the registration form and that this information is up to date.
1.7. The Operator may make amendments to the Privacy Policy without obtaining the prior consent from the User. The new amended version of the Privacy Policy comes into effect from the moment it is posted on the Website, unless provided otherwise by the new version of the Privacy Policy. The text of the Privacy Policy is available to the Internet Users on the following website: https://apexcom.net.
1.8. This Privacy Policy is applicable only to this Website. The Website does not control and is not liable to or responsible for the websites of third parties where the User may be taken to by clicking on the links available on the Website.
2. GOALS OF PERSONAL DATA COLLECTION AND PROCESSING
2.1. The Website collects and stores only those personal data that are necessary to provide and deliver services (in execution of the agreements with the User).
2.2. The Website can use the User’s personal data for the following purposes:
2.2.1. to identify the party to a contract or agreement;
2.2.2. to deliver personalized services to the User;
2.2.3. to maintain communication with the User, including notification, sending requests and information concerning the use of the Services, service delivery, and processing the requests and queries sent by the User;
2.2.4 to provide the User access to free materials (including webinars), for the purpose of information distribution, including advertising materials about sales promotions, events and special offers, for the purpose of obtaining the User’s feedback, comments and suggestions, for the purpose of conducting surveys for improving the communication with the Operator’s current and potential clients.
2.2.5. to improve the quality and usability of the services provided; to develop new services.
3. CONDITIONS OF PERSONAL DATA PROCESSING
3.1. Personal data authorized for processing under this Privacy Policy is provided by the User by ordering services on the Website and in the process of obtaining services, or when taking part in the Operator’s survey, or when being granted access by the Operator to free materials:
- family name, first name, patronymic;
- address;
- contact information (phone number; e-mail; Telegram nickname; social media account names)
- bank details for payments.
4. MEASURES TAKEN BY THE OPERATOR TO PROCESS PERSONAL DATA
4.1. For personal data processing the Operator at its own discretion maintains the following legal, organizational and technical measures to protect such data from an unauthorized or accidental access, destruction, modification, blocking, copying, sharing, and release as well as other illegal actions with respect to personal data:
4.1.1 identifies personal data security threats when working with personal data in information systems of personal data;
4.1.2. takes organizational and technical measures to provide personal data security, including the security of personal data during their processing in information systems of personal data, in line with the personal data security requirements corresponding to the levels of data security set by the Government of the Russian Federation;
4.1.3. assesses the effectiveness of the measures taken to ensure personal data security prior to the deployment of the information system of personal data;
4.1.4. ensures timely detection of unauthorized access to personal data and takes the necessary prevention and corrective actions;
4.1.5. recovers personal data that were modified or destroyed as a result of a personal data breach;
4.1.6. sets rules regulating authorization of the access to personal data processed in the information system of personal data, ensures registration and accounting of all the actions performed with personal data in the information system of personal data;
4.1.7. ensures control over personal data security measures and the level of security of the information systems of personal data;
4.1.8. publishes the Privacy Policy on the Website and ensures unrestricted access to it;
4.1.9. exerts internal control over the compliance of personal data processing with the requirements of the personal data protection legislation;
4.1.10. determines personal data storage locations;
4.2. The personal data processed by the Operator are only accessible to such persons whose job duties entail work with such information and documents. The Operator may give access to the personal data to its employees according to the procedure established by the legislation of the Russian Federation. The Operator limits this information only to those personal data that are necessary for the purposes of the relevant processing.
4.3. The Operator may grant access to users’ personal data in the following cases:
4.3.1 if it is required or permitted by the laws of the Russian Federation;
4.3.2 if the User has consented to their personal data transfer to the recipient.
5. RIGHTS AND OBLIGATIONS OF THE PARTIES
5.1. The User is entitled to the following:
5.1.1. to receive from the Operator information about their personal data processing;
5.1.2. to request restriction of the processing of their personal data if the User considers them inaccurate, incomplete, outdated, obtained illegally or if these data cannot be deemed necessary for the declared purpose of processing as well as to maintain measures to protect their rights as provided by law;
5.1.3. to protect their rights and legal interests through legal proceedings;
5.1.4. at their own discretion to grant the Operator access to their personal data for processing under the terms and conditions of this Privacy Policy;
5.1.5 to request from the Operator access to the information about their personal data processing.
5.2. The User’s right of access to their personal data may be limited by the federal laws, including cases where the User’s access to their personal data violates the rights and legal interests of third parties.
5.3. The Operator undertakes to do the following:
5.3.1. to use the information provided exclusively for the purposes set out in this Privacy Policy;
5.3.2. to keep personal information confidential; not to disclose the User’s personal information without prior written permission obtained from the User; not to sell, exchange, publish or disclose it by any other means, except for the means indicated in this Privacy Policy;
5.3.3. to take precautionary measures to protect the User’s personal data;
5.4.3. to block the User’s personal data immediately after receiving the request from the User or their legal representatives or a competent authority in charge of the monitoring and enforcement of the Personal Data Law during the period of data checking in case inaccurate personal data or unauthorized activities are detected.
6. IDENTIFICATION FILES (COOKIES)
6.1. The Website may use client-side files that contain user information (hereinafter – cookies).
6.2. Cookies are necessary to use the Website and navigate around it, to ensure the correct operation of the Website.
6.3. Cookies may contain information about the User’s actions on the Website, including the information entered by the User, and are used in accordance with the provisions of the Privacy Policy. The data stored in cookies are available only for the Website and cannot be read from other websites that the User visits.
6.4. By using the Website, the User gives consent to cookie storage by the Website through the corresponding standard mechanisms available on the local browser of the User’s device.
7. SETTLEMENT OF DISPUTES
7.1. A dispute between the User and Operator can be settled before any lawsuit is filed. In this case a textual proposal (claim) for out-of-court settlement of the dispute is submitted.
7.2. The recipient of the claim shall notify the claimant in writing of the results of the claim consideration within 30 consecutive days from the date of its receipt.
7.3. If the dispute cannot be resolved, it shall be referred to the court in accordance with the current legislation of the Russian Federation.
7.4. The Privacy Policy and the relationship between the User and Operator are subject to the current legislation of the Russian Federation.
8. FEEDBACK AND OPERATOR’S DETAILS
8.1. Any questions or suggestions concerning the Privacy Policy as well as personal data processing should be sent to the email address specified in item 8.2. of this Privacy Policy.
8.2. Operator’s details:
Limited Liability Company ‘APEXCOM’
OGRN 1217700163746
INN 7726475790 KPP 772601001117105
Address: 117105, Moscow, Novodanilovskaya Embankment 6, building 1, 10th floor
current acc. 40702810555030001216 in
Bank VTB (PAO), Branch ‘Tsentralny’, BIK 044525411
correspondent acc. 30101810145250000411
E-mail: info@apexcom.net
