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Analysis of user behavior patterns in Russian E-commerce and off-line stores…
… allows you to calculate the probability of purchasing a specific segment of users and find new customers in the network
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experience
in Asia Pacific
1. Definitions.
1.1. Personal data - any information relating directly or indirectly to a specific or determinable natural person (citizen). Those. such information, in particular, may include: name, year, month, date and place of birth, address, information about family, social, property status, information about education, profession, income, information about the state of health, as well as other information, allowing to collectively determine and identify the personal data owner.
1.2. Processing personal data - any action (operation) or a set of actions (operations) with personal data committed with or without automation. Such actions (operations) include: collection, receipt, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
1.3. Personal data security - the protection of personal data from unlawful or accidental access to it, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data.
2. The scope of the privacy policy.
2.1. Privacy Policy (hereinafter referred to as the Policy) of DV Group LLC, registration number 1187746443763 (hereinafter referred to as the Company) determines the procedure for the processing and protection by the Company of personal data in order to comply with their safety in strict accordance with the requirements of the law.
2.2. The policy is publicly available for any personal data owner (data subject).
2.3. The Policy applies to all personal data of subjects processed in the Company using automation tools and without using such tools.
2.4. The policy is strictly implemented by all employees of the Company.
2.5. The company requires its partners and service providers to strictly comply with the requirements of the law on the processing and protection of personal data.
3. Subjects of personal data.
3.1. The company processes the personal data of the following subjects:
Individual customers (potential customers) of the Company;
representatives of customers - legal entities (potential customers) of the Company;
representatives of legal entities of counterparties of the Company;
subjects with which independent contractor agreement are concluded;
employees of the Company;
former employees of the Company;
candidates for filling the vacant positions of the Company.
4. The rights of the personal data owner.
4.1. A data subject whose personal data is processed by the Company has the right to receive from the Company:
confirmation of the fact of processing personal data by the Company;
legal grounds and goals for the processing of personal data;
information on the methods used by the Company for processing personal data;
name and location of the Company;
information about persons who have access to personal data or to whom personal data may be disclosed on the basis of an agreement with the Company or on the basis of federal law;
a list of processed personal data relating to the citizen from whom the request was received and the source of their receipt, unless otherwise provided by federal law;
information about the periods of processing personal data, including the periods of their storage;
information on the procedure for the exercise by a citizen of the rights stipulated by the legislation on personal data;
information on the ongoing or alleged cross-border transfer of personal data;
name and address of the person processing personal data on behalf of the Company;
other information provided by the legislation on personal data.
4.2. A data subject whose personal data is processed by the Company has the right to demand the clarification of its personal data, its blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing;
4.3. A data subject whose personal data is processed by the Company has the right to withdraw its consent to the processing of personal data;
4.4. A data subject whose personal data is processed by the Company has the right to demand the elimination of unlawful actions of the Company in relation to its personal data;
4.5. A data subject whose personal data is processed by the Company has the right to appeal the actions or inaction of the Company to the Federal Service for Supervision of Communications, Information Technologies and Mass Communications (Roskomnadzor) or in a court of law if a citizen considers that the Company is processing his personal data in violation of the requirements of the legislation on personal data or otherwise violates his rights and freedoms;
4.6. A data subject whose personal data is processed by the Company, it has the right to protect its rights and legitimate interests, including compensation for losses and / or compensation for non-pecuniary damage in court.
4.7. A data subject whose personal data is processed by the Company has the right to receive clarifications on issues of personal data processing, including clarifying personal data and withdrawing its consent to the processing of personal data by sending an official request to the Company by Russian Post at:
Russia, 115054, Moscow, ul. Dubininskaya 57 bldg. 1, office 406 "DVspace" - to Danshin Alexei Borisovich.
In the text of the request you must specify:
FULL NAME;
the number of the main document proving the identity of the personal data owner or his representative, information on the date of issue of the said document and the body that issued it OR any other data that makes it possible to uniquely identify the personal data owner (in particular, phone number, email address);
information confirming your participation in relations with the Company or information that otherwise confirms the fact that the Company processed personal data;
signature of the subject (or its legal representative). I
f the request is sent in electronic form, then it must be executed in the form of an electronic document and signed by electronic signature in accordance with the legislation of the Russian Federation.
5. Purpose of processing personal data.
5.1. The Company’s personal data is processed for, but not limited to:
ensuring compliance with the laws of the Russian Federation and other regulatory legal acts;
for the execution of a contract to which either the beneficiary or guarantor is a personal data owner, as well as for the conclusion of a contract at the initiative of the personal data owner or the contract under which the personal data owner will be the beneficiary or guarantor;
registration and maintenance of the account on the websites of the Company;
processing applications for services;
sales of services;
information about the services.
6. The procedure for processing personal data.
6.1. The Company carries out processing and ensuring the security of personal data in accordance with the requirements of the Constitution of the Russian Federation, Federal Law No. 152-ФЗ “On Personal Data”, by-laws, other determining cases and features of the processing of personal data of federal laws of the Russian Federation, guidelines and methodological documents of the FSTEC of Russia and the FSB of Russia (legislation on personal data).
6.2. When processing personal data, the Company takes the necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access to it, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data, such as the:
identification of threats to the security of personal data during their processing in personal data information systems;
the application of organizational and technical measures to ensure the security of personal data when they are processed in personal data information systems necessary to fulfill the requirements for the protection of personal data, the implementation of which ensures the levels of personal data security established by the Government of the Russian Federation;
the use of the procedures for assessing the conformity of information protection facilities that have passed in the established manner;
assessment of the effectiveness of measures taken to ensure the security of personal data prior to the commissioning of the personal data information system;
detection of unauthorized access to personal data and taking measures;
restoration of personal data modified or destroyed due to unauthorized access to them;
registration and accounting of all actions performed with personal data in the personal data information system;
control over measures taken to ensure the security of personal data and the level of security of personal data information systems;
accounting of machine carriers of personal data;
organization of access control to the territory of the Company;
placement of technical means of processing personal data within the protected territory;
maintenance of technical means of protection, signaling in constant readiness;
monitoring of user actions, conducting proceedings on violations of personal data security requirements;
in order to coordinate actions to ensure the security of personal data in the Company, persons responsible for ensuring the security of personal data have been appointed.
6.3. If the personal data owner is located in the territory where consent is required to transfer personal data to another jurisdiction, then using the services of the Company, he gives the Company his explicit and unambiguous consent to such transfer or storage, and / or processing of information in other specified jurisdictions, including Russian Federation.
6.4. Society processing Provides personal data only if at least one of the following conditions exists:
the processing of personal data is carried out with the consent of the personal data owner to the processing of his personal data;
-processing of personal data is necessary to achieve the goals stipulated by law, to implement and fulfill the functions, powers and duties assigned to the operator by the legislation of the Russian Federation;
the processing of personal data is necessary for the execution of a contract to which either the beneficiary or guarantor is the personal data owner, as well as for the conclusion of an agreement on the initiative of the personal data owner or the contract under which the personal data owner will be the beneficiary or guarantor;
the processing of personal data is necessary to exercise the rights and legitimate interests of the Company or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data owner;
the processing of personal data is carried out, access to an unlimited number of persons to which is provided by the personal data owner or at his request;
the processing of personal data owner to publication or mandatory disclosure in accordance with federal law is carried out.
6.5. The Company has the right to entrust the processing of personal data of citizens to third parties, on the basis of an agreement concluded with these persons. Persons who process personal data on behalf of the Company undertake to comply with the requirements of the legislation on personal data. For each person, a list of actions with personal data that will be performed by such a person is determined, the purposes of processing, the obligation of such a person to maintain confidentiality and ensure the security of personal data during their processing is established, as well as the requirements for the protection of processed personal data are indicated.
6.6. In cases established by the legislation of the Russian Federation, the Company has the right to transfer personal data of citizens.
6.7. The company destroys or depersonalizes personal data when the processing goals are achieved or if the need to achieve the processing goal is lost.
7. Responsibility.
7.1. In case of failure to comply with the provisions of this Policy, the Company shall be liable in accordance with the current legislation of the Russian Federation.
The current version of the “Privacy Policy of DV Group LLC” regarding the processing of personal data is published on the website www.dvgroup.com.
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