Digital and Privacy Policy
Policy on the processing of personal data and privacy
This document “Policy on the processing of personal data and confidentiality” (hereinafter referred to as the “Policy”) represents the rules for the use of PROPTEC COMPANY LLC (hereinafter referred to as the “Company”) of Users’ personal information.
1. General policy provisions
1.1. This Policy applies to all information that the Company and/or its affiliates, including all persons included in the same group with the Company, may receive about the user while using any of the Company’s sites, services, programs and products (hereinafter referred to as — Services), as well as during the execution by the Company / its affiliates of any agreements and contracts concluded with the user in connection with the use of the Services. The user’s consent to provide personal data (personal information), given by him in accordance with this Policy within the framework of relations with one of the persons included in the group of persons of the Company, applies to all persons included in this group of persons.
1.2. The company is an Operator for the processing of personal data in the sense laid down by the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”.
1.3. When registering on the Company’s websites (including and/or filling out forms that require entering personal data, the User, of his own free will and in his own interests, gives written consent to the following methods of processing his personal data in accordance with conditions defined by this document: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
1.4. This Policy, including the interpretation of its provisions and the procedure for adoption, execution, amendment and termination, is subject to the laws of the Russian Federation.
1.5. Here and further in the Policy, terms and definitions are used, the interpretation of which is made in accordance with the current legislation of the Russian Federation, business customs, or scientific doctrine.
1.6. For the purposes of this Policy, the “User” means any individual - a visitor to the Company’s websites who provides personal data using information and telecommunication networks.
1.7. This Policy applies to all Company websites where its text is posted.
1.8. Use of the Services means the User’s unconditional consent to this Policy and the conditions for processing his personal information specified therein, namely, to perform the actions provided for in clause 3, part 1, art. 3 of the Federal Law of July 27, 2006 N 152-FZ "On Personal Data" both without and with the use of automation tools, and confirms that by giving such consent, he acts freely, of his own will and in his own interest; in case of disagreement with these terms, the user must refrain from using the Services.
2. Personal information
2.1. Personal information in this Policy means:
2.1.1. personal data that Users provide to the Company when filling out information fields on websites, including when filling out a contact form, when subscribing to newsletters:
Full Name;
E-mail address;
Phone numbers;
Information about the legal entity of the applicant.
2.2. In addition to personal information, the Company collects technical data, namely:
technical data that is automatically transmitted by the device with which Users use the sites, including technical characteristics of the device, IP address, information stored in cookies that were sent to the User's device, browser information, date and time of access to the site, addresses of the requested pages and other similar information.
3. Purposes and methods of data processing
3.1. The Company processes Users’ personal data solely for
the purposes for which they were provided, including:
to register Users to provide access to certain sections of the site;
providing Users with information about the Company, services and events;
improving the quality of the Services, ease of use, developing new Services;
communication with the User when contacting;
organizing the participation of Users in ongoing events and surveys; sending Users news materials about the Company; targeting advertising materials based on contextual data analysis; conducting statistical and other studies based on anonymized data;
fulfilling the powers and duties assigned to the Company by the legislation of the Russian Federation;
for other purposes with the consent of the User.
3.2. The company processes technical data to: ensure the functioning and security of the sites; improving the quality of sites.
The company does not place personal data of Users in publicly available sources. The Company does not make decisions that give rise to legal consequences for Users or otherwise affect their rights and legitimate interests based solely on automated processing of personal data.
3.3. The storage of personal data in a form that makes it possible to identify the subject of personal data is carried out no longer than required by the purposes of their processing, unless the storage period for personal data is established by current legislation. Personal data is subject to destruction or depersonalization upon achievement of the purposes of processing or in the event of the loss of the need to achieve these purposes, unless otherwise provided by current legislation.
3.4. In order to communicate with the User regarding the use of services, the Company may use communication through messenger applications and social networks on the Internet, provided that the User provides identifying information.
4. User Rights
4.1. Ensuring the protection of the rights of personal data subjects is fundamental
the principle of the Company’s work on this issue.
4.2. In order to ensure the protection of the rights and freedoms of Users, the Company may, at the User’s request:
confirm the processing of this User’s personal data and provide the opportunity to review them within 30 days from the date
receiving a request;
inform about the source of receipt and composition of the User’s personal data that the Company processes;
inform about the legal grounds, purposes, terms and methods of processing the User’s personal data;
make the necessary changes to personal data if the User confirms that they are incomplete, inaccurate or irrelevant, within 7 working days from the date of receipt of confirmation, and notify the User of the changes made;
provide the name or surname, first name, patronymic and address of persons who, with the consent of the User, may be entrusted with the processing of personal data; exclude the User from the distribution of news and information materials; stop processing the User’s personal data within 30 days from the date of receipt of the withdrawal of consent, unless there are other legal grounds for the processing of personal data provided for by the legislation of the Russian Federation;
stop processing the User’s personal data if it is confirmed that the processing is unlawful, and notify the User of the measures taken;
destroy the User’s personal data if it is confirmed that they were illegally obtained or do not correspond to the stated purposes of processing, within 7 working days from the date of receipt of the relevant confirmation, and notify the User of the measures taken;
answer the User’s questions regarding his personal data processed by the Company.
5. Methods of communication with the Company
5.1. The user can contact the Company with a request regarding the processing of personal data by sending a letter with the subject “Request for personal data” (or “Withdrawal of consent to the processing of personal data” in case of withdrawal of consent to the processing of personal data) to the email address: info@kaizen
6. Security of personal data
6.1. To ensure the security of Users’ personal data during their processing, the Company undertakes to take necessary and sufficient legal, organizational and technical measures to protect personal data from unauthorized or accidental access to it, its destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions in relation to personal data.
6.2. In order to ensure adequate protection of personal data, the Company assesses the harm that may be caused in the event of a violation
security of personal data, as well as identify current threats to the security of personal data during their processing in information systems.
6.3. Company employees who have access to personal data are familiar with this Policy and local regulations on the security of personal data.
7. Cross-border transfer of personal data
7.1. The Company does not transfer Users’ personal data to foreign countries. The company takes all necessary measures to guarantee the confidentiality and security of personal data.
7.2. Cross-border transfer of personal data to the territory of foreign states is carried out only with the written consent of the User, or for the execution of an agreement to which the User is a party, as well as in other cases provided for by the legislation of the Russian Federation on personal data.
8. Termination of processing of personal data
8.1. The Company stops processing the User’s personal data:
upon the occurrence of conditions for termination of the processing of personal data or upon expiration of the established deadlines;
upon achievement of the purposes of their processing or in case of loss, it is necessary efforts in achieving these goals;
at the request of the User, if the personal data being processed is illegally obtained or is not necessary for the stated purpose of processing;
in case of detection of unlawful processing of personal data, if it is impossible to ensure the legality of processing;
upon expiration of the User’s consent to the processing of personal data or in the event of withdrawal of such consent, unless there are other legal grounds for the processing of personal data provided for by the legislation of the Russian Federation;
in case of liquidation of the Company. 9. Links to third party sites
9.1. The Company's websites may contain links to third-party sites and services over which it does not control. The Company is not responsible for the security or privacy of any information collected by third party sites or services.
10. Change of Policy
10.1. The Company may update the Policy as necessary. The Company recommends that Users periodically check the relevance of this Policy. By continuing to use the site after changing the Policy, the User confirms acceptance of the changes made.
10.2. This document will reflect any changes to the Company’s personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
10.3. The current version of the Policy is freely available on the Internet at**