Policy with regard to personal data processing Policy with regard to personal data processing

This Policy is a document that determines the policy of a limited liability company “AI WAO”, PSRN 1147847415187, TIN 7801644225 (hereinafter referred to as the Company) with regard to processing of personal data that the Company can obtain from subjects who, one way or another, use the website vitacoin.net in the Internet (hereinafter referred to as the Website) and / or any services available through the Website (hereinafter referred to as the Service(s)). Relevant subjects of personal data are hereinafter collectively referred to as “Users” and individually as the “User”.

Use of the Website (in particular, any of its pages) and / or use of any Services means an unconditional acceptance by the User of this Policy and the conditions of processing his/her personal data specified herein; in case of disagreement with these conditions, the User must withhold using the Website and / or Services. .

  1. GENERAL

    Within the framework of this Policy, personal data of the User means:

    1. Data which is automatically transmitted by a User’s device through which he/she gets access to the Website and / or Services, including IP address, cookie data, information about a User’s browser (or similar program), specifications of User’s hardware and software, date and time of access to the Website and / or Services, addresses of requested pages and other similar information.
    2. Personal data (name, surname, patronymic, telephone number, e-mail address, etc.) that the User provides by him/herself when completing a registration procedure on the Website, as a result of which a unique account (member area) is created for the User, or other similar information;
    3. This Policy applies exclusively to the Website and the Services available through the Website. The Company does not control and is not responsible for third party websites to which the User can go through links available on the Website.
  2. PURPOSE OF USERS’ PERSONAL DATA PROCESSING

    Processing by the Company of the users’ personal data is carried out exclusively for the following purposes:

    1. Provision of services by the Company to users in accordance with a contract concluded with the User (a User Agreement), in particular, ensuring availability of the Services for users (including by sending information digests (news gatherings), analytical materials to users’ email addresses);
    2. Creation of unique user accounts (member areas) on the Website;
    3. Transferring to users of reference and marketing information, including marketing information of third party partners of the Company;
    4. Providing users with an opportunity to feedback with the Company, including that for the purpose of users support;
    5. Providing users with advice on issues related to the services provided by the Company.
  3. CONDITIONS FOR USERS’ PERSONAL DATA PROCESSING AND ITS TRANSFER TO THE THIRD PARTIES

    Transfer of users’ personal data in accordance with this clause is carried out for the purpose of providing marketing information to users by relevant third parties who are partners of the Company, i.e. information on goods, services, works, property rights offered by the third parties, etc. Corresponding third parties have the right to process users’ personal data pursuant to compliance with the requirements for protection of processed personal data set by legislative restatement by such ways as: systematization, accumulation, storage, clarification (renewal, amendment), extraction, use, transfer (granting, access), depersonalization, blocking, removal and destruction of the User’s personal data.

    1. A legal basis for processing of personal data of users by the Company is an agreement concluded between users and the Company (a user agreement, a current version of which is always published on the Website at the address: https://vitacoin.net/en/info/ agreement/) and / or a user’s consent to process his/her personal data. In case of absence of any agreement between the Company and the User, when sending any information to the Company, including filling out a feedback form posted on the Website, the User agrees to processing of all personal data provided by him/her.
    2. The Company processes only that users’ personal data, content and scope of which correspond to the purposes of processing specified in Section 2 hereof. In order to achieve the purposes specified in Section 2 hereof, the Company processes the following personal data of the User: name, surname, patronymic, telephone number, e-mail address, and other data that the User has independently wished to communicate to the Company, as well as data specified in clause 1.1.2. hereof due to technical features of the Internet.
    3. In some cases, in particular for payback of user’s money in circumstances determined by a User Agreement, the Company can process personal data of the user, which shall be additionally provided (sent) by the user him/herself. Provision (sending) of relevant personal data by the User to the Company means the User’s consent to processing the specified personal data by the Company.
    4. During processing of personal data, the Company has the right to: collect, record, classify, accumulate, store, update (renew, amend), extract, use, transfer (grant, access), depersonalize, block, delete or destruct users’ personal data.
    5. As a general rule, users’ personal data is processes by automation facilities. In exceptional cases, processing of users’ personal data can be carried out without use of these facilities, while complying to the current legislation.
    6. Users’ personal data is processed during the period necessary to achieve the purpose specified in Section 2 of this Policy and / or during the period stipulated in the contract concluded with the User (User Agreement) and / or during the period provided for by the current legislation.
    7. Confidentiality of users’ personal data is maintained, except for cases of voluntary provision by the User of information about him/herself for general access of the unlimited range of persons.
    8. The User hereby fully agrees with possibility of cross-border transfer by the Company of any of his/her personal data to third parties located in the territory of foreign countries that are parties of the Council of Europe Convention for Protection of Individuals with regard to Automatic Processing of Personal Data, as well as other foreign countries that provide adequate protection of rights of personal data subjects outside the Russian Federation (the names of such third parties will be communicated by the Company to the User additionally by sending a message to the User’s email address specified by him/her when creating a User account on the Website).
    9. Upon achievement of the purpose / expiration of a period for processing of personal data / in case of the User’s withdrawal of his/her his consent to processing of personal data, the User’s personal data shall be irrevocably destructed.
    10. The Company takes the necessary organizational and technical measures to protect users’ personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties. Processing of users’ personal data is carried out only by the authorized employees of the Company who have undertaken to maintain confidentiality of such data and who have been acquainted with the provisions of the Russian Federation legislation on personal data, including requirements for protection of personal data, as well as with the local acts of the Company with respect to processing of personal data. Processing of users’ personal data is carried out by the Company using databases located in the territory of the Russian Federation.
  4. RIGHTS AND OBLIGATIONS OF THE WEBSITE USER
    1. Users have the right to:
      1. Require clarification of their personal data, their renewal, blocking or destruction;
      2. Obtain a list of their personal data processed by the Company, a source of its receipt, information on processing of their personal data, including a period of its storage, and other information on processing of their personal data, provided for by the current legislation;
      3. Require notification of all persons who have previously been informed of incorrect or incomplete personal data about all amendments or revisions made;
      4. Appeal in the prescribed manner against unlawful actions or inactions while processing of their personal data.
    2. Users agree to provide only accurate personal data.
    3. In the event that the Company processes personal data on the basis of consent to processing of personal data, such consent shall be issued by the User for the entire period required by the Company to achieve the purpose of processing specified in the Section 2 hereof.
  5. OBLIGATIONS OF THE COMPANY

    The Company undertakes to:

    1. Use received personal data exclusively for the purposes specified in Section 2 hereof;
    2. Clarify the user’s personal data, update, block or destruct it and eliminate any violations of the law committed in the course of processing of personal data in the manner prescribed by the applicable law.
    3. Provide a user, in case of receipt from him/her or his/her legal representative of a request meeting the legal requirements, with a list of personal data of this user processed by the Company, a source of their receipt, information on processing of personal data, including periods of its storage, and other information on processing of his/her personal data, provided by the current legislation;
    4. Block the personal data related to a relevant user from the moment of receipt of a request from a user or his/her legal representative or an authorized body for protection of rights of personal data subjects for an examination period in case of revealing of unreliable personal data or illegal actions;
    5. Take measures provided by the legislation and local acts of the Company to protect confidentiality of users’ personal data;
    6. Ensure that data is kept confidential, not disclose it without prior written consent of the User, as well as not to sell, exchange, publish or otherwise disclose the User’s personal data, except as provided in this Policy and the applicable law;
  6. SUPPLEMENTARY CONDITIONS
    1. Any inquiries / appeals of users / legal representatives of users / authorized state bodies regarding processing of personal data by the Company, including inaccuracy of processed personal data, illegality of their processing, withdrawal of consent and a user’s access to his/her data shall be sent in writing (by registered and / or money letter, express mail) to the Company’s address: 199178, 18th line of Vasilievsky island, 29, building A, premises 1H, room 166, St. Petersburg, Russia or by sending an appropriate request / appeal to a following e-mail address of the Company: info@vitacoin.net. A request / appeal must contain at least: surname, first name, patronymic of a user, e-mail address of a user and other information in cases provided for by the current legislation.
    2. The Company has the right to amend this Policy without the User’s consent.
    3. A new revision of the Policy shall come into force from the moment of its posting on the Website, unless otherwise provided by a new revision of the Policy.
    4. The current revision of this Policy is always publicly available on the Website at the address: https://vitacoin.net/en/info/policy/.