1. General Provisions
This Personal Data Processing Policy is drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ “On Personal Data” (hereinafter – the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure security of personal data, undertaken by Limited Liability Company “Multitex”, located at: 124482, Moscow, Zelenograd, Savelkinskiy proezd, 4, floor. 13, room XXI, room 4, office 4I (hereinafter – the Operator).
1.1. The Operator’s principal purpose and condition of its activity is to ensure observance of human and citizen’s rights and freedoms in processing of their personal data, including protection of rights to privacy, personal and family secrets.
1.2 The present policy of the Operator in relation to the processing of personal data (hereinafter – the Policy) applies to all information that the Operator can obtain about the visitors of the website https://multitex.su (hereinafter – the Site) and its services. The services of the Website are, inter alia, chatbots in messengers, specified on the Website (hereinafter – Services). The Operator has no control over and is not responsible for the websites of third parties, to which the User can go through the links available on the Site.
1.3 The Policy defines the order of personal data processing and measures to ensure security of personal data of individuals who use the services of the website https://multitex.su and its Services (hereinafter – the Users), undertaken by the Operator. This Policy is available at: https://multitex.su/privacy-policy.
1.4 The use of the Website and its Services means the User’s unconditional consent to this Policy, as well as the terms of the User’s Consent to the processing of personal data, which were in effect at the time of the actual use of the site. In case of disagreement with this Policy, as well as with the terms of the User’s Consent to the processing of personal data, the User must refrain from using the Site and its Services.
1.5 Terms you may encounter in our Policy:
1.5.1 Automated processing of personal data – processing of personal data by means of computer technology.
1.5.2 Blocking of personal data – temporary termination of processing of personal data (except when the processing is necessary to clarify personal data).
1.5.3 Website, Site means 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://multitex.su/.
1.5.4. Personal data information system – a set of personal data contained in databases of personal data and information technology and technical means for its processing.
1.5.5 De-identification of personal data – actions, as a result of which it is impossible to determine, without using additional information, what personal data belongs to a particular User or other subject of personal data.
1.5.6 Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
1.5.7. Operator – a state body, municipal body, legal entity or individual, independently or together with other persons, arranging and/or carrying out processing of personal data, as well as determining the purpose of processing of personal data, composition of personal data to be processed, actions (operations) performed with personal data.
1.5.8. Personal Data – any information relating directly or indirectly to a particular or defined User of the website https://multitex.su/.
1.5.9. Personal data, authorized by the subject of personal data for distribution – personal data, access to which is provided to the general public by the subject of personal data by giving consent to the processing of personal data, authorized by the subject of personal data for distribution in the manner prescribed by law on personal data (hereinafter – personal data, authorized for distribution).
1.5.10. User – any visitor to the website https://multitex.su/.
1.5.11. Provision of personal data – actions aimed at disclosure of personal data to a certain person or a certain circle of persons.
1.5.12. Dissemination of personal data – any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or familiarization of personal data to an unlimited circle of persons, including publication of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.
1.5.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual or foreign legal entity.
1.5.14. Destruction of personal data – any actions, as a result of which personal data is destroyed irretrievably with impossibility of further restoration of personal data content in information system of personal data and/or destruction of material media of personal data.
2.1 By providing the services of using the Website and its services (hereinafter – the Website Services) the Operator, acting reasonably and in good faith, considers that the User:
– has all necessary rights enabling him/her to use this Site;
– is aware that the information on the Site posted by the User about himself/herself may become available to other users of the Site and Internet users, may be copied and distributed by such users;
– is aware that certain types of information transmitted by him/her to other Users cannot be deleted by the User himself/herself;
– is familiar with this Policy, agrees with it and accepts the rights and obligations specified in it.
2.2 The Operator doesn’t check the reliability of the received (collected) information about the users, except for the cases when such check is necessary for the purpose of fulfillment of obligations to the user.
3. Purposes of information processing
3.1 The operator uses the personal information received in order to:
– providing access to the Site, its Services,
– determining the User’s location for security purposes, fraud prevention,
– confirming the accuracy and completeness of the personal information provided by the User,
– analysis of User interaction with the Site,
– evaluating the use of the Site,
– preparing reports on site activity,
– establishing feedback with the User, including sending notices, requests regarding the use of the Site,
– provision of services,
– processing of inquiries and requests from the User,
– providing effective customer and technical support to the User in case of problems associated with the use of the Site,
– advertising activities with the User’s consent,
– in cases where the law provides for mandatory storage of personal information for a period specified by law.
4. List of actions performed by the Operator with the received personal data
Security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures required to meet in full the requirements of applicable laws in the field of personal data protection.
4.1 The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes and destroys personal data.
4.2 The User’s data is collected when he fills out feedback forms on the site. The Company collects other data on its own when the User uses the Website. In some cases, the collection of the User’s Personal Data starts from the moment the User gains access to the Website (for example, when loading the Web page or launching an application).
4.3 The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.
4.4 The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons. When processing personal data, the operator ensures the confidentiality of personal data.
4.5 The User’s personal data will never, under no circumstances be transferred to third parties, except in cases related to the implementation of the current legislation or if the subject of personal data has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil law contract.
4.7 The prohibitions established by the subject of personal data on the transfer (other than providing access), as well as on the processing or processing conditions (other than access) of personal data allowed for distribution, are not valid in cases of processing of personal data in the state, public and other public interests, defined by Russian legislation.
4.8. The operator shall store personal data in a form that allows to identify the subject of personal data, no longer than required by the purposes of personal data processing, unless the period of personal data storage is established by federal law, the contract, a party to which, a beneficiary or a guarantor under which the subject of personal data is.
4.9 A condition for termination of personal data processing may be achievement of personal data processing objectives, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject or a requirement to terminate personal data processing, as well as detection of unlawful personal data processing.
5. Composition of user information
5.1.1 Personal information, which the User provides about himself/herself or in the process of using the Site and its Services, including the User’s personal data.
5.1.2 The data which are automatically transmitted to the Services while using them with the software installed on your device, including your IP-address, cookie data, information about your browser (or other software through which you access the Services), the technical characteristics of the hardware and software used by the User, the date and time of access to the Services, the addresses of the requested pages and other similar information.
5.2 The Operator collects the following personal data on the Site, including but not limited to:
– contact phone number(s);
– E-mail address(es);
– IP-address, information about the sites the User visits and the information the User requests, information about the User’s activity on the Internet;
– data related to messenger and social networking accounts (username, photo, signature text, location, social networking page address, etc.), which are uploaded and published when uploading content, and when authenticating with a social networking account and when submitting a request for feedback
– any other personal data that the User communicated in any way.
6. Principles of personal data processing
6.1 Processing of personal data shall be performed on a lawful and fair basis.
6.2 Processing of personal data shall be subject to the consent of the data subject to the processing of his/her personal data.
6.3 Processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purpose of personal data collection is not permitted.
6.4 Databases containing personal data, which are processed for purposes incompatible with each other, shall not be combined.
6.5 Only personal data that meets the purposes of processing shall be processed.
6.6 When processing personal data, the accuracy of personal data, its sufficiency and, if necessary, relevance to the purposes of personal data processing shall be ensured. The operator shall take the necessary measures and/or ensure that they are taken to remove or clarify incomplete or inaccurate data.
7. Rights and obligations of the parties
7.1 Users have the right:
– receive information relating to the processing of their personal data, except in cases stipulated by federal laws. Information is provided to the subject of personal data by the operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except in cases where there are legitimate grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
– to demand from the Operator the clarification of his personal data, their blocking or destruction in case the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take statutory measures to protect his rights
– to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
– to withdraw the Consent to the processing of personal data, as well as to request the termination of processing of personal data;
– to exercise other rights provided by the legislation of the Russian Federation.
7.2 The User must:
– provide the Operator with reliable data about himself/herself;
– inform the Operator of the clarification (updating, modification) of their personal data.
7.3. Persons, who provided the Operator with false information about themselves, or information about the other subject of personal data without the consent of the latter, shall be liable in accordance with the laws of the Russian Federation.
7.4 The operator has the right:
– receive from the subject of personal data reliable information and/or documents containing personal data;
– in case of withdrawal by the personal data subject of the Consent to personal data processing, as well as in case of sending a request to terminate personal data processing, the Operator shall be entitled to continue processing of personal data without the consent of the personal data subject, if 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 obligations provided by the Personal Data Law and regulations adopted in accordance therewith, unless otherwise provided by the Personal Data Law or other federal laws.
7.5 The Operator shall:
– use the information received solely for the purposes specified in this Policy.
– provide the subject of personal data at his/her request information relating to the processing of his/her personal data;
– organize the processing of personal data in the manner prescribed by applicable laws of the Russian Federation;
– respond to requests and inquiries of subjects of personal data and their legal representatives, in accordance with the requirements of the Law on personal data;
– communicate to the authorized agency for protection of personal data subjects, at the request of such body, the necessary information within the period prescribed by the Act
– publish or otherwise ensure unrestricted access to this Policy on personal data processing
– take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other unlawful acts in relation to personal data
– cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in the manner and cases provided by the Personal Data Law
– perform other duties provided by the Personal Data Law.
8.1. In case of loss or disclosure of confidential information, the Operator shall not be liable if the confidential information:
8.1.1. Became in the public domain prior to its loss or disclosure.
8.1.2 Was received from a third party prior to its receipt by the Operator.
8.1.3 Was disclosed with the User’s consent.
9. Technology “Cookies”
9.1 Processing cookies
Cookies are small pieces of data that websites request from the browser used on a User’s computer or mobile device. Cookies are stored locally on the Internet User’s computer or mobile device. The Company collects and processes cookies in relation to Users visiting the Company’s Website.
9.2 The following types of cookies are used on the Site:
– strictly necessary cookies / technical cookies: these cookies are necessary for the operation of the Site and the provision of Services to the User; among other things, they allow the Company to identify the User’s hardware and software, including the type of browser;
– statistical / analytical cookies: these cookies allow you to recognize Users, count their number and collect information such as transactions made on the sites, including information about the web pages visited and the content the User receives;
– technical cookies: these cookies collect information about how users interact with the website, which allows identifying errors and testing new features to improve the performance of the Services;
– functional cookies: these cookies allow you to provide certain features to facilitate your use of the Sites, such as saving preferences (such as language and location);
– (third-party) tracking/advertising cookies: these cookies collect information about traffic sources, pages visited, and advertisements displayed to the User. They allow the display of advertisements that may be of interest to the User based on analysis of the information collected about the User. They are also used for statistical and research purposes.
9.3 The information collected by cookies placed on the User’s device can be transmitted and available to the Operator, as well as companies that own Yandex.Metrika and Google Analytics web analytics services.
9.4 The use of information outside the Site, collected with the help of cookies, for advertising purposes, if any, can be the subject of separate user agreements, available on websites of third parties. The Company and/or third parties may also provide the User with the opportunity to refuse personalization of advertisements, which may be subject to regulation by law and regulations applicable to such products and offers.
This Site uses web analytics service Yandex Metrika provided by Yandex LLC, 16 L. Tolstoy St., Moscow, Russia, 119021 (hereinafter – Yandex).
9.6 For the purposes specified above, this website uses Google Analytics, Google, Inc. (Google) web analytics service, so the information generated by the cookie (including your IP address) will be sent to a Google server in the USA and will be stored there. For more information about Google Analytics cookies, see here.
The transfer of personal data to Google LLC takes place via Google Analytics.
Google https://policies.google.com/privacy?hl=ru&gl=ZZ. Purposes of the transfer of personal data: To collect statistics on visitors to the Site.
9.7 If you do not want cookies to be used on the devices you use, you can change your browser security settings. Please note that changes to your security settings must be made on a browser-by-browser basis, and the setting methods used may vary. However, keep in mind that if you reject or disable cookies, you may lose functionality on some websites. Moreover, disabling cookies or categories of cookies does not remove them from your browser; you will have to do this yourself in your browser.
10. Requests from users
10.1 The User may send their request to the Operator in one of the following convenient ways: in writing to the following address: 4, Savelkinskiy proezd. 13, room XXI, room 4, office 4I or in the form of an electronic document in accordance with the laws of the Russian Federation by e-mail: firstname.lastname@example.org.
10.2 The operator undertakes to consider and send a response to the user’s request within 30 days of the receipt of the request.
10.3 All correspondence received by the Operator from users (requests in written or electronic form) refers to information of limited access and is not disclosed without the written consent of the User. Personal data and other information about the User, who sent the request, can’t be used without the User’s special consent, except for answering the received request or in cases, which are directly stipulated by the legislation.
11. Final provisions
11.1 The User can get any clarifications on the questions of interest concerning the processing of their personal data by contacting the Operator by e-mail at email@example.com.
11.2 The current version of the Policy, which is a public document, is available to any Internet user. The Operator has the right to make changes to this Policy without the consent of the User. The new Policy takes effect upon its posting on the Website at the permanent address https://multitex.su/privacy-policy. The Policy is valid indefinitely until it is replaced by a new version.
WARNING – The personal data of visitors to the Site is processed for the purposes of its operation. If you do not agree, the visitor must leave this resource, otherwise you consent to the processing of your personal data.
Last update: 03/03/2023