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Personal Data Processing Policy
privacy
privacy policy
1. General provisions
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" of July 27, 2006 (hereinafter, the "Personal Data Law") and sets out the procedure for processing personal data and the measures taken by “POWERBEE” LLC (hereinafter, the "Operator") to ensure the security of personal data.
1.1. The Operator's paramount objective and condition for carrying out its activities is the observance of the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the rights to privacy and to personal and family secrecy.
1.2. This Operator's policy regarding the processing of personal data (hereinafter, the "Policy") applies to all information that the Operator may obtain about visitors to the website https://www.powbee.ru/.
2. Basic terms used in the Policy
2.1. Automated processing of personal data — processing of personal data by means of computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://www.powbee.ru/.
2.4. Personal data information system — the totality of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions as a result of which it is impossible, without the use of additional information, to determine whether personal data belong to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://www.powbee.ru/.
2.9. Personal data authorized by the personal data subject for dissemination — personal data to which the personal data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data authorized by the personal data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter, "personal data authorized for dissemination").
2.10. User — any visitor to the website https://www.powbee.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including the publication of personal data in the mass media, posting on information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, or to a foreign individual or foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed, making it impossible to further restore the content of the personal data in the personal data information system, and/or the physical media containing personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;
— if the personal data subject withdraws consent to the processing of personal data or submits a request to stop the processing of personal data, the Operator may continue processing the personal data without the consent of the personal data subject where there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject, at their request, with information regarding the processing of their personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects, at the request of that body, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, and dissemination, as well as from other unlawful actions in relation to personal data;
— stop the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— perform other obligations provided for by the Personal Data Law.
4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand that the operator clarify, block, or destroy their personal data if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and take measures provided for by law to protect their rights;
— make prior consent a condition for the processing of personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data and submit a request to stop the processing of personal data;
— appeal against unlawful actions or omissions of the Operator in processing their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with reliable information about themselves;
— notify the Operator of any clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the latter's consent, shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data are processed on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.
5.3. Combining databases containing personal data that are processed for mutually incompatible purposes is not permitted.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. The personal data processed must not be excessive in relation to the stated purposes of their processing.
5.6. When personal data are processed, their accuracy, sufficiency, and, where necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period of the personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. The processed personal data are destroyed or depersonalized upon achievement of the purposes of processing or if the need to achieve these purposes ceases to exist, unless otherwise provided by federal law.
6. Purposes of personal data processing
Purpose of processing
informing the User by sending emails
Personal data
7.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to carry out the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice or the enforcement of a judicial act or an act of another body or official that is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or of a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data are processed to which the personal data subject has granted access to an unlimited number of persons, or which have been made so accessible at their request (hereinafter, "publicly available personal data").
7.7. Personal data are processed that are subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for the collection, storage, transfer, and other types of personal data processing
The security of the personal data processed by the Operator is ensured through the implementation of the legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies are found in the personal data, the User may update them independently by sending a notice to the Operator's email address info@powbee.ru marked "Personal data update".
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by contract or current legislation.
The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator by email at the Operator's email address info@powbee.ru marked "Withdrawal of consent to personal data processing".
8.5. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User shall review the said documents on their own in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (other than the provision of access), as well as on the processing or conditions of processing (other than obtaining access), of personal data authorized for dissemination do not apply where personal data are processed in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period of the personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon achievement of the purposes of personal data processing, expiration of the personal data subject's consent, withdrawal of consent by the personal data subject or a request to stop the processing of personal data, or detection of unlawful processing of personal data.
9. List of actions performed by the Operator with the personal data received
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the information obtained over information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. Before commencing the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfers of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of personal data
The Operator and other persons who have gained access to personal data must not disclose personal data to third parties or disseminate them without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The User may obtain any clarification on matters of interest regarding the processing of their personal data by contacting the Operator by email at info@powbee.ru.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at https://www.powbee.ru/privacy.
This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" of July 27, 2006 (hereinafter, the "Personal Data Law") and sets out the procedure for processing personal data and the measures taken by “POWERBEE” LLC (hereinafter, the "Operator") to ensure the security of personal data.
1.1. The Operator's paramount objective and condition for carrying out its activities is the observance of the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the rights to privacy and to personal and family secrecy.
1.2. This Operator's policy regarding the processing of personal data (hereinafter, the "Policy") applies to all information that the Operator may obtain about visitors to the website https://www.powbee.ru/.
2. Basic terms used in the Policy
2.1. Automated processing of personal data — processing of personal data by means of computer technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except where processing is necessary to clarify personal data).
2.3. Website — a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://www.powbee.ru/.
2.4. Personal data information system — the totality of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data — actions as a result of which it is impossible, without the use of additional information, to determine whether personal data belong to a specific User or other personal data subject.
2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state body, municipal body, legal entity, or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://www.powbee.ru/.
2.9. Personal data authorized by the personal data subject for dissemination — personal data to which the personal data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data authorized by the personal data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter, "personal data authorized for dissemination").
2.10. User — any visitor to the website https://www.powbee.ru/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including the publication of personal data in the mass media, posting on information and telecommunication networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, or to a foreign individual or foreign legal entity.
2.14. Destruction of personal data — any actions as a result of which personal data are irreversibly destroyed, making it impossible to further restore the content of the personal data in the personal data information system, and/or the physical media containing personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The Operator has the right to:
— receive reliable information and/or documents containing personal data from the personal data subject;
— if the personal data subject withdraws consent to the processing of personal data or submits a request to stop the processing of personal data, the Operator may continue processing the personal data without the consent of the personal data subject where there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
— provide the personal data subject, at their request, with information regarding the processing of their personal data;
— organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
— respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects, at the request of that body, with the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, and dissemination, as well as from other unlawful actions in relation to personal data;
— stop the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
— perform other obligations provided for by the Personal Data Law.
4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the personal data subject by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— demand that the operator clarify, block, or destroy their personal data if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and take measures provided for by law to protect their rights;
— make prior consent a condition for the processing of personal data for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data and submit a request to stop the processing of personal data;
— appeal against unlawful actions or omissions of the Operator in processing their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
— exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
— provide the Operator with reliable information about themselves;
— notify the Operator of any clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another personal data subject without the latter's consent, shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of personal data processing
5.1. Personal data are processed on a lawful and fair basis.
5.2. The processing of personal data is limited to the achievement of specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.
5.3. Combining databases containing personal data that are processed for mutually incompatible purposes is not permitted.
5.4. Only personal data that meet the purposes of their processing are subject to processing.
5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. The personal data processed must not be excessive in relation to the stated purposes of their processing.
5.6. When personal data are processed, their accuracy, sufficiency, and, where necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data are stored in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period of the personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor. The processed personal data are destroyed or depersonalized upon achievement of the purposes of processing or if the need to achieve these purposes ceases to exist, unless otherwise provided by federal law.
6. Purposes of personal data processing
Purpose of processing
informing the User by sending emails
Personal data
- last name, first name, patronymic
- email address
- phone numbers
- Federal Law No. 149-FZ "On Information, Information Technologies and Information Protection" of July 27, 2006
- Sending informational emails to the email address
7.1. Personal data are processed with the consent of the personal data subject to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to carry out the functions, powers, and duties imposed on the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice or the enforcement of a judicial act or an act of another body or official that is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or of a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data are processed to which the personal data subject has granted access to an unlimited number of persons, or which have been made so accessible at their request (hereinafter, "publicly available personal data").
7.7. Personal data are processed that are subject to publication or mandatory disclosure in accordance with federal law.
8. Procedure for the collection, storage, transfer, and other types of personal data processing
The security of the personal data processed by the Operator is ensured through the implementation of the legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or where the personal data subject has given the Operator consent to transfer the data to a third party for the performance of obligations under a civil law contract.
8.3. If inaccuracies are found in the personal data, the User may update them independently by sending a notice to the Operator's email address info@powbee.ru marked "Personal data update".
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by contract or current legislation.
The User may withdraw their consent to the processing of personal data at any time by sending a notice to the Operator by email at the Operator's email address info@powbee.ru marked "Withdrawal of consent to personal data processing".
8.5. All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or the User shall review the said documents on their own in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.
8.6. Prohibitions established by the personal data subject on the transfer (other than the provision of access), as well as on the processing or conditions of processing (other than obtaining access), of personal data authorized for dissemination do not apply where personal data are processed in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. When processing personal data, the Operator ensures the confidentiality of personal data.
8.8. The Operator stores personal data in a form that makes it possible to identify the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period of the personal data is established by federal law or by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon achievement of the purposes of personal data processing, expiration of the personal data subject's consent, withdrawal of consent by the personal data subject or a request to stop the processing of personal data, or detection of unlawful processing of personal data.
9. List of actions performed by the Operator with the personal data received
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the information obtained over information and telecommunication networks.
10. Cross-border transfer of personal data
10.1. Before commencing the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfers of personal data (such notification is sent separately from the notification of the intention to process personal data).
10.2. Before submitting the above notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to which the cross-border transfer of personal data is planned.
11. Confidentiality of personal data
The Operator and other persons who have gained access to personal data must not disclose personal data to third parties or disseminate them without the consent of the personal data subject, unless otherwise provided by federal law.
12. Final provisions
12.1. The User may obtain any clarification on matters of interest regarding the processing of their personal data by contacting the Operator by email at info@powbee.ru.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at https://www.powbee.ru/privacy.
PRIVACY POLICY FOR THE "POWBEECRM" MOBILE APPLICATION
1. DEFINITIONS
"Law" means the Federal Law of the Russian Federation "On Personal Data", as amended and supplemented, as well as other legislative acts of the Russian Federation.
"Controller" means the person responsible for processing and protecting the Personal Data of Users located in the EU within the meaning of the General Data Protection Regulation of April 27, 2016 (hereinafter, the "GDPR").
"Mobile Application" means software (with all existing add-ons and improvements) designed to run on smartphones, tablets, watches, and other mobile devices and developed for a specific platform (iOS, Android, Windows Phone, etc.). For the purposes of this Policy, the Mobile Application means the following software: PowBee CRM.
"Personal Data" means the set of personal data and/or non-personalized information about the User provided by the User to the Right Holder and/or automatically collected by the Right Holder and/or third parties.
"Policy" means this Privacy Policy of the Mobile Application (with all existing additions and amendments).
"User" means a legal entity or individual who has downloaded the Mobile Application to a smartphone, tablet, watch, or any other mobile device and/or has activated such Mobile Application on one of the said devices.
"User Agreement" means the agreement concluded between the Right Holder and the User regarding the procedure, rules, and specifics of the User's use of the Mobile Application. The User accedes to such agreement and has no right to make and/or demand any changes or additions to it.
"Right Holder" means the following person who holds the exclusive rights to the Mobile Application: "PowerBee" LLC.
"Processor" means the person who, within the meaning of the GDPR, stores and/or processes Personal Data received from Users on behalf of the Controller.
"Cookies" means small files sent by a mobile application or website and placed on the User's smartphones, tablets, watches, and other mobile devices to improve the performance of such applications or websites and the quality of the content posted in them.
2. RELATIONS COVERED BY THE POLICY
General provisions
This Policy is used and applies exclusively to Personal Data received from the User in connection with their use of the Mobile Application. The provisions of this Policy are intended to:
(1) define the kinds and types of Personal Data received, the areas and purposes of use (processing) of Personal Data, and the sources from which such Personal Data are obtained; and
(2) define the User's rights with respect to protecting the confidentiality of the Personal Data they transmit; and
(3) identify the persons responsible for processing and storing Personal Data, as well as the third parties to whom such data are disclosed (in whole or in part).
The rules of this Policy do not apply to the processing by third parties of Personal Data voluntarily provided by the User. By installing and/or activating the Mobile Application on a smartphone, tablet, watch, or other mobile device, the User agrees to the terms of this Policy and gives the Right Holder consent to collect, process, retain, and store Personal Data in the manner and on the terms provided for by this Policy. If the User does not agree with the terms of the Policy and/or does not understand certain terms of the Policy, the User must immediately stop using the Mobile Application.
User rights regarding personal data protection
In connection with the provision of Personal Data, the User automatically acquires the following rights:
(1) to receive data regarding their processing (the grounds and purposes of such processing, the processing methods used, information about the persons who have access to them or to whom they may be disclosed on the basis of a contract or the Law).
(2) to receive data on the location and identification details of the persons processing the Personal Data.
(3) to receive data on the Personal Data retention periods.
(4) to receive data on any completed or intended cross-border transfer of Personal Data.
(5) to receive information on the location and identification details of the persons storing the Personal Data.
(6) to appeal against the actions or omissions of the Right Holder to the authorized body for the protection of the rights of personal data subjects or in court.
(7) to obtain, through the courts, compensation for damages and/or compensation for moral harm resulting from violations by the Right Holder and/or third parties of the User's rights to the protection of their Personal Data.
(8) to exercise other rights in the field of personal data protection provided for by the Law or the provisions of this Policy.
3. LIST OF PERSONAL DATA COLLECTED
Non-personalized information about users
In connection with the use of the Mobile Application, the Right Holder may automatically collect and process the following non-personalized information about the User:
(1) information about traffic, the possible number of clicks made, logs, and other data.
(2) information about the User's location (geolocation). The User may disable geolocation at any time by changing the settings of the device used to log in to the Mobile Application. Geolocation is used by the Mobile Application only while the User is actively using the application. When the User exits the Mobile Application, geolocation stops functioning.
(3) information about the device (identification number, mobile network operator) used to log in, the operating system, platform, browser type and other browser information, and IP address.
Personal data about users
The Right Holder does not collect any personal data about Users that would allow them to be identified.
Use of cookies
This Mobile Application uses certain Cookies to store the IP address, User preferences, or the type of device used for the purposes of (1) keeping statistics of site visits and traffic, and (2) personalizing the data displayed on the User's screen, and (3) storing the data necessary to identify the User, including when accessing from different devices, and (4) displaying advertising in accordance with the User's interests and preferences. The Mobile Application may use both its own Cookies belonging to the Right Holder and third-party Cookies.
The Mobile Application uses the following Cookies:
(1) Technical (functional) Cookies, which are needed to control traffic and data transmission, to identify Users and provide the User with access to the content of the Mobile Application, and without which the use of the Mobile Application is functionally limited, as well as to prevent recommendations that do not match the User's interests.
(2) Geolocation Cookies, which are needed to determine the User's location in order to personalize the content displayed on the screen of their device in the Mobile Application.
(3) Third-party Cookies, which are set by third parties with the User's permission and are intended for conducting statistical research regarding the User's behavior on the Internet and/or sending personalized advertising or marketing materials to the User and/or providing goods or services.
The User has the right to disable Cookies in the Mobile Application at any time by changing certain settings on their smartphone, tablet, watch, or other mobile device. Such disabling does not entail any restriction or change in the User's access to the functionality and/or content of the Mobile Application. To disable Cookies, the following steps must be taken: ________
4. PURPOSES OF COLLECTING AND PROCESSING PERSONAL DATA
Definition of processing purposes
Personal Data are collected and processed for the following purposes:
(1) to analyze the User's behavior and identify the User's preferences for certain types of content.
(2) to ensure the prompt and correct operation of the Mobile Application, improve the functioning of the Mobile Application, improve the content of the Mobile Application, and improve the internal architecture and functionality of the Mobile Application.
(3) to identify the User.
(4) to comply with the requirements of the Law.
(5) to determine the User's location.
(6) to provide technical support for the Mobile Application and to identify and resolve problems in its operation.
(7) to maintain contact with the User (communication).
(8) to fulfill other obligations of the Right Holder to the User.
(9) for any other purposes, subject to obtaining separate consent from the User.
Personal Data are processed on the basis of the following principles: (1) lawfulness of the purposes and methods of processing; and (2) good faith; and (3) consistency of the purposes of Personal Data processing with the purposes predetermined and declared when such Personal Data were collected; and (4) consistency of the volume and nature of the Personal Data processed with the stated purposes of their processing.
Conditions for personal data processing
Personal Data are processed in the following cases: (1) the User's consent has been obtained; or (2) the Right Holder is achieving the purposes provided for by an international treaty or the Law; or (3) the User has made their Personal Data available to an unlimited number of persons; or (4) the Right Holder is fulfilling other obligations to the User, including, but not limited to, providing certain content to the User; or (5) the life or health of the User needs to be saved and consent to the processing of their Personal Data cannot be obtained in advance.
If Personal Data are depersonalized so that the User cannot be directly or indirectly identified, subsequent use and disclosure of such data to third parties is permitted, and the rules of this Policy no longer apply to them.
The Right Holder takes all possible measures to protect the confidentiality of the Personal Data received, except where the User has made such data publicly available.
Personal Data are processed both with and without the use of automation tools.
5. THIRD-PARTY ACCESS TO PERSONAL DATA
Disclosure of personal data to third parties
The Right Holder has the right to disclose Personal Data (1) to its affiliates, branches, and representative offices established both in the Russian Federation and in other states; (2) to the legal successors of the Right Holder that have arisen as a result of its liquidation, reorganization, or bankruptcy and that have acquired the exclusive rights to the Mobile Application; (3) to third parties solely for the purpose of enabling the User to receive certain content or access to it; (4) to third parties where the User has consented to the disclosure, transfer, or processing of their Personal Data, as well as in other cases expressly provided for by the Law or this Policy.
The Right Holder discloses Personal Data only if (1) it is confident that the third parties will comply with the terms of this Policy and take the same measures to protect the confidentiality of Personal Data as the Right Holder itself takes, and (2) consent to such disclosure has been previously expressed by the User and/or is permitted under the Law.
6. ADVERTISING
Advertising in the mobile application
The Right Holder does not place advertising in the Mobile Application.
7. SUBMITTING COMPLAINTS AND REQUESTS TO THE RIGHT HOLDER
Request to stop processing personal data
Each User has the right to object to the Right Holder to the processing and/or storage of their Personal Data. Such an objection may be expressed as follows:
Request to info@powbee.ru
Request for information about personal data
If the User has questions related to the application or use of this Policy, or to the procedure and/or method of processing Personal Data, the User may ask such a question as follows:
Request to info@powbee.ru
Modification (updating, supplementing, correction) or deletion of personal data
The User has the right to modify or delete Personal Data at any time by sending a special request to the Right Holder at the following address: info@powbee.ru.
The Right Holder has the right to refuse to modify or delete Personal Data if such actions would result in (1) a violation of the rules of this Policy; or (2) a violation of the Law; (3) or if the nature of the Personal Data is such that they constitute evidence in any legal proceedings arising between the Right Holder and the User.
8. PERIODS AND PROCEDURE FOR STORING PERSONAL DATA
Storage is carried out by third parties on behalf of the Right Holder. The User consents to the storage of their Personal Data by third parties on behalf of the Right Holder, provided that such third parties maintain the confidentiality of the Personal Data received. The functions of storing the Information are entrusted to the following person: ________ (hereinafter, the "Custodian"). Personal Data are stored in the territory of the Russian Federation.
Storage is carried out for the entire period necessary to achieve the stated purposes of Personal Data processing.
The Right Holder undertakes to destroy or depersonalize Personal Data immediately after the purposes of their processing have been achieved.
9. ACCESS OF MINORS TO THE MOBILE APPLICATION
Users in the Russian Federation
The Mobile Application is intended for use by persons over 18 years of age.
If the User is a minor, they must immediately stop using this Mobile Application.
Users in the European Union
The Mobile Application is intended for use by persons aged 16 and over.
If the Right Holder becomes aware that the User's age does not meet the permissible age for using the Mobile Application, the Right Holder undertakes to immediately block such User's access to the Mobile Application.
10. PROCEDURE FOR PROTECTING PERSONAL DATA
Protecting the confidentiality of Personal Data is a primary and important task for the Right Holder. The Right Holder adheres to all required international standards, rules, and recommendations for the protection of Personal Data.
The Right Holder has implemented a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access by third parties.
11. USERS IN THE EUROPEAN UNION
General provisions
Since the Mobile Application is available to users from the European Union, the Right Holder undertakes to additionally comply with the provisions of the GDPR.
The Controller within the meaning of this Policy is the Right Holder. The Processor within the meaning of this Policy is the Custodian pursuant to Article 8 of the Policy.
The Right Holder stores Personal Data for a reasonable period necessary to achieve the purposes of processing, but not less than the period established for storing a particular type of Personal Data by the local legislation of the European Union member state in which the Mobile Application is available. Upon expiration of the storage period, the Right Holder undertakes to immediately destroy or depersonalize such data.
Official representative
Since the Controller is located outside the European Union, the following person is appointed as its official representative for the protection of Users' Personal Data in the European Union: Oleg Markgraf, address: 109004,
Moscow, 43 Nikoloyamskaya St., bldg. 4, premises 3/9; contact details: info@powbee.ru.
User rights in the field of personal data protection
Under Chapter 3 of the GDPR, Users located in the European Union have the following rights with respect to the protection of Personal Data: (1) the right to receive information about their Personal Data ("the right to be informed"); and (2) the right of access to their Personal Data ("the right of access"); and (3) the right to rectification of Personal Data ("the right to rectification"); and (4) the right to erasure of Personal Data ("the right to erasure"); and (5) the right to restrict the processing of Personal Data ("the right to restrict processing"); and (6) the right to transfer Personal Data to third parties ("the right to data portability"); and (7) the right to object ("the right to object").
12. FINAL PROVISIONS
Availability of the policy text
Users may review the terms of this Policy at the following link: powbee.ru/privacy.
This Policy may be translated into a foreign language for Users who access the Mobile Application from outside the Russian Federation. In the event of any discrepancy between the original text (in Russian) and its translation, the original language shall prevail.
This version of the Policy is effective as of February 10, 2021.
Amendments and additions to the policy
This Policy may be amended from time to time. The Right Holder bears no liability to the User for changing the terms of this Policy without the User's permission and/or consent.
The User undertakes to regularly review the provisions of this Policy for possible amendments or additions.
Applicable law
This Policy has been developed in accordance with the current personal data protection legislation of the Russian Federation, in particular Federal Law No. 152-FZ "On Personal Data" of July 27, 2006 (as amended and supplemented) and Federal Law No. 242-FZ "On Amendments to Certain Legislative Acts of the Russian Federation Regarding the Clarification of the Procedure for Processing Personal Data in Information and Telecommunication Networks" of July 21, 2014 (as amended and supplemented), as well as the provisions of the General Data Protection Regulation (GDPR) of April 27, 2016.
Risk of disclosure
Regardless of the measures taken by the Right Holder to protect the confidentiality of the personal data received, the User is hereby deemed duly informed that no transmission of Personal Data over the Internet can be guaranteed to be secure, and therefore the User makes any such transmission at their own risk.
1. DEFINITIONS
"Law" means the Federal Law of the Russian Federation "On Personal Data", as amended and supplemented, as well as other legislative acts of the Russian Federation.
"Controller" means the person responsible for processing and protecting the Personal Data of Users located in the EU within the meaning of the General Data Protection Regulation of April 27, 2016 (hereinafter, the "GDPR").
"Mobile Application" means software (with all existing add-ons and improvements) designed to run on smartphones, tablets, watches, and other mobile devices and developed for a specific platform (iOS, Android, Windows Phone, etc.). For the purposes of this Policy, the Mobile Application means the following software: PowBee CRM.
"Personal Data" means the set of personal data and/or non-personalized information about the User provided by the User to the Right Holder and/or automatically collected by the Right Holder and/or third parties.
"Policy" means this Privacy Policy of the Mobile Application (with all existing additions and amendments).
"User" means a legal entity or individual who has downloaded the Mobile Application to a smartphone, tablet, watch, or any other mobile device and/or has activated such Mobile Application on one of the said devices.
"User Agreement" means the agreement concluded between the Right Holder and the User regarding the procedure, rules, and specifics of the User's use of the Mobile Application. The User accedes to such agreement and has no right to make and/or demand any changes or additions to it.
"Right Holder" means the following person who holds the exclusive rights to the Mobile Application: "PowerBee" LLC.
"Processor" means the person who, within the meaning of the GDPR, stores and/or processes Personal Data received from Users on behalf of the Controller.
"Cookies" means small files sent by a mobile application or website and placed on the User's smartphones, tablets, watches, and other mobile devices to improve the performance of such applications or websites and the quality of the content posted in them.
2. RELATIONS COVERED BY THE POLICY
General provisions
This Policy is used and applies exclusively to Personal Data received from the User in connection with their use of the Mobile Application. The provisions of this Policy are intended to:
(1) define the kinds and types of Personal Data received, the areas and purposes of use (processing) of Personal Data, and the sources from which such Personal Data are obtained; and
(2) define the User's rights with respect to protecting the confidentiality of the Personal Data they transmit; and
(3) identify the persons responsible for processing and storing Personal Data, as well as the third parties to whom such data are disclosed (in whole or in part).
The rules of this Policy do not apply to the processing by third parties of Personal Data voluntarily provided by the User. By installing and/or activating the Mobile Application on a smartphone, tablet, watch, or other mobile device, the User agrees to the terms of this Policy and gives the Right Holder consent to collect, process, retain, and store Personal Data in the manner and on the terms provided for by this Policy. If the User does not agree with the terms of the Policy and/or does not understand certain terms of the Policy, the User must immediately stop using the Mobile Application.
User rights regarding personal data protection
In connection with the provision of Personal Data, the User automatically acquires the following rights:
(1) to receive data regarding their processing (the grounds and purposes of such processing, the processing methods used, information about the persons who have access to them or to whom they may be disclosed on the basis of a contract or the Law).
(2) to receive data on the location and identification details of the persons processing the Personal Data.
(3) to receive data on the Personal Data retention periods.
(4) to receive data on any completed or intended cross-border transfer of Personal Data.
(5) to receive information on the location and identification details of the persons storing the Personal Data.
(6) to appeal against the actions or omissions of the Right Holder to the authorized body for the protection of the rights of personal data subjects or in court.
(7) to obtain, through the courts, compensation for damages and/or compensation for moral harm resulting from violations by the Right Holder and/or third parties of the User's rights to the protection of their Personal Data.
(8) to exercise other rights in the field of personal data protection provided for by the Law or the provisions of this Policy.
3. LIST OF PERSONAL DATA COLLECTED
Non-personalized information about users
In connection with the use of the Mobile Application, the Right Holder may automatically collect and process the following non-personalized information about the User:
(1) information about traffic, the possible number of clicks made, logs, and other data.
(2) information about the User's location (geolocation). The User may disable geolocation at any time by changing the settings of the device used to log in to the Mobile Application. Geolocation is used by the Mobile Application only while the User is actively using the application. When the User exits the Mobile Application, geolocation stops functioning.
(3) information about the device (identification number, mobile network operator) used to log in, the operating system, platform, browser type and other browser information, and IP address.
Personal data about users
The Right Holder does not collect any personal data about Users that would allow them to be identified.
Use of cookies
This Mobile Application uses certain Cookies to store the IP address, User preferences, or the type of device used for the purposes of (1) keeping statistics of site visits and traffic, and (2) personalizing the data displayed on the User's screen, and (3) storing the data necessary to identify the User, including when accessing from different devices, and (4) displaying advertising in accordance with the User's interests and preferences. The Mobile Application may use both its own Cookies belonging to the Right Holder and third-party Cookies.
The Mobile Application uses the following Cookies:
(1) Technical (functional) Cookies, which are needed to control traffic and data transmission, to identify Users and provide the User with access to the content of the Mobile Application, and without which the use of the Mobile Application is functionally limited, as well as to prevent recommendations that do not match the User's interests.
(2) Geolocation Cookies, which are needed to determine the User's location in order to personalize the content displayed on the screen of their device in the Mobile Application.
(3) Third-party Cookies, which are set by third parties with the User's permission and are intended for conducting statistical research regarding the User's behavior on the Internet and/or sending personalized advertising or marketing materials to the User and/or providing goods or services.
The User has the right to disable Cookies in the Mobile Application at any time by changing certain settings on their smartphone, tablet, watch, or other mobile device. Such disabling does not entail any restriction or change in the User's access to the functionality and/or content of the Mobile Application. To disable Cookies, the following steps must be taken: ________
4. PURPOSES OF COLLECTING AND PROCESSING PERSONAL DATA
Definition of processing purposes
Personal Data are collected and processed for the following purposes:
(1) to analyze the User's behavior and identify the User's preferences for certain types of content.
(2) to ensure the prompt and correct operation of the Mobile Application, improve the functioning of the Mobile Application, improve the content of the Mobile Application, and improve the internal architecture and functionality of the Mobile Application.
(3) to identify the User.
(4) to comply with the requirements of the Law.
(5) to determine the User's location.
(6) to provide technical support for the Mobile Application and to identify and resolve problems in its operation.
(7) to maintain contact with the User (communication).
(8) to fulfill other obligations of the Right Holder to the User.
(9) for any other purposes, subject to obtaining separate consent from the User.
Personal Data are processed on the basis of the following principles: (1) lawfulness of the purposes and methods of processing; and (2) good faith; and (3) consistency of the purposes of Personal Data processing with the purposes predetermined and declared when such Personal Data were collected; and (4) consistency of the volume and nature of the Personal Data processed with the stated purposes of their processing.
Conditions for personal data processing
Personal Data are processed in the following cases: (1) the User's consent has been obtained; or (2) the Right Holder is achieving the purposes provided for by an international treaty or the Law; or (3) the User has made their Personal Data available to an unlimited number of persons; or (4) the Right Holder is fulfilling other obligations to the User, including, but not limited to, providing certain content to the User; or (5) the life or health of the User needs to be saved and consent to the processing of their Personal Data cannot be obtained in advance.
If Personal Data are depersonalized so that the User cannot be directly or indirectly identified, subsequent use and disclosure of such data to third parties is permitted, and the rules of this Policy no longer apply to them.
The Right Holder takes all possible measures to protect the confidentiality of the Personal Data received, except where the User has made such data publicly available.
Personal Data are processed both with and without the use of automation tools.
5. THIRD-PARTY ACCESS TO PERSONAL DATA
Disclosure of personal data to third parties
The Right Holder has the right to disclose Personal Data (1) to its affiliates, branches, and representative offices established both in the Russian Federation and in other states; (2) to the legal successors of the Right Holder that have arisen as a result of its liquidation, reorganization, or bankruptcy and that have acquired the exclusive rights to the Mobile Application; (3) to third parties solely for the purpose of enabling the User to receive certain content or access to it; (4) to third parties where the User has consented to the disclosure, transfer, or processing of their Personal Data, as well as in other cases expressly provided for by the Law or this Policy.
The Right Holder discloses Personal Data only if (1) it is confident that the third parties will comply with the terms of this Policy and take the same measures to protect the confidentiality of Personal Data as the Right Holder itself takes, and (2) consent to such disclosure has been previously expressed by the User and/or is permitted under the Law.
6. ADVERTISING
Advertising in the mobile application
The Right Holder does not place advertising in the Mobile Application.
7. SUBMITTING COMPLAINTS AND REQUESTS TO THE RIGHT HOLDER
Request to stop processing personal data
Each User has the right to object to the Right Holder to the processing and/or storage of their Personal Data. Such an objection may be expressed as follows:
Request to info@powbee.ru
Request for information about personal data
If the User has questions related to the application or use of this Policy, or to the procedure and/or method of processing Personal Data, the User may ask such a question as follows:
Request to info@powbee.ru
Modification (updating, supplementing, correction) or deletion of personal data
The User has the right to modify or delete Personal Data at any time by sending a special request to the Right Holder at the following address: info@powbee.ru.
The Right Holder has the right to refuse to modify or delete Personal Data if such actions would result in (1) a violation of the rules of this Policy; or (2) a violation of the Law; (3) or if the nature of the Personal Data is such that they constitute evidence in any legal proceedings arising between the Right Holder and the User.
8. PERIODS AND PROCEDURE FOR STORING PERSONAL DATA
Storage is carried out by third parties on behalf of the Right Holder. The User consents to the storage of their Personal Data by third parties on behalf of the Right Holder, provided that such third parties maintain the confidentiality of the Personal Data received. The functions of storing the Information are entrusted to the following person: ________ (hereinafter, the "Custodian"). Personal Data are stored in the territory of the Russian Federation.
Storage is carried out for the entire period necessary to achieve the stated purposes of Personal Data processing.
The Right Holder undertakes to destroy or depersonalize Personal Data immediately after the purposes of their processing have been achieved.
9. ACCESS OF MINORS TO THE MOBILE APPLICATION
Users in the Russian Federation
The Mobile Application is intended for use by persons over 18 years of age.
If the User is a minor, they must immediately stop using this Mobile Application.
Users in the European Union
The Mobile Application is intended for use by persons aged 16 and over.
If the Right Holder becomes aware that the User's age does not meet the permissible age for using the Mobile Application, the Right Holder undertakes to immediately block such User's access to the Mobile Application.
10. PROCEDURE FOR PROTECTING PERSONAL DATA
Protecting the confidentiality of Personal Data is a primary and important task for the Right Holder. The Right Holder adheres to all required international standards, rules, and recommendations for the protection of Personal Data.
The Right Holder has implemented a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access by third parties.
11. USERS IN THE EUROPEAN UNION
General provisions
Since the Mobile Application is available to users from the European Union, the Right Holder undertakes to additionally comply with the provisions of the GDPR.
The Controller within the meaning of this Policy is the Right Holder. The Processor within the meaning of this Policy is the Custodian pursuant to Article 8 of the Policy.
The Right Holder stores Personal Data for a reasonable period necessary to achieve the purposes of processing, but not less than the period established for storing a particular type of Personal Data by the local legislation of the European Union member state in which the Mobile Application is available. Upon expiration of the storage period, the Right Holder undertakes to immediately destroy or depersonalize such data.
Official representative
Since the Controller is located outside the European Union, the following person is appointed as its official representative for the protection of Users' Personal Data in the European Union: Oleg Markgraf, address: 109004,
Moscow, 43 Nikoloyamskaya St., bldg. 4, premises 3/9; contact details: info@powbee.ru.
User rights in the field of personal data protection
Under Chapter 3 of the GDPR, Users located in the European Union have the following rights with respect to the protection of Personal Data: (1) the right to receive information about their Personal Data ("the right to be informed"); and (2) the right of access to their Personal Data ("the right of access"); and (3) the right to rectification of Personal Data ("the right to rectification"); and (4) the right to erasure of Personal Data ("the right to erasure"); and (5) the right to restrict the processing of Personal Data ("the right to restrict processing"); and (6) the right to transfer Personal Data to third parties ("the right to data portability"); and (7) the right to object ("the right to object").
12. FINAL PROVISIONS
Availability of the policy text
Users may review the terms of this Policy at the following link: powbee.ru/privacy.
This Policy may be translated into a foreign language for Users who access the Mobile Application from outside the Russian Federation. In the event of any discrepancy between the original text (in Russian) and its translation, the original language shall prevail.
This version of the Policy is effective as of February 10, 2021.
Amendments and additions to the policy
This Policy may be amended from time to time. The Right Holder bears no liability to the User for changing the terms of this Policy without the User's permission and/or consent.
The User undertakes to regularly review the provisions of this Policy for possible amendments or additions.
Applicable law
This Policy has been developed in accordance with the current personal data protection legislation of the Russian Federation, in particular Federal Law No. 152-FZ "On Personal Data" of July 27, 2006 (as amended and supplemented) and Federal Law No. 242-FZ "On Amendments to Certain Legislative Acts of the Russian Federation Regarding the Clarification of the Procedure for Processing Personal Data in Information and Telecommunication Networks" of July 21, 2014 (as amended and supplemented), as well as the provisions of the General Data Protection Regulation (GDPR) of April 27, 2016.
Risk of disclosure
Regardless of the measures taken by the Right Holder to protect the confidentiality of the personal data received, the User is hereby deemed duly informed that no transmission of Personal Data over the Internet can be guaranteed to be secure, and therefore the User makes any such transmission at their own risk.
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