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Privacy policy

General provisions

This Privacy Policy (hereinafter – Policy) of the Limited liability company “National Digital Aggregator” (hereinafter – the Company, NDA LLC) has been prepared for the website of the Company zvonkodigital.ru (hereinafter – Privacy policy) and applies to all information, including personal data of the users of the website, in accordance to the provisions of Federal law of 27.07.2006 №152-FZ ” On personal data” (hereinafter – FZ№ 152) and international legislative standards of personal data protection (hereinafter – Personal information), that NDA LLC can obtain on the User during his using of the website of the Company.

The Policy determines the order of processing of the personal data and other information and protection measures of protection of the personal data and other information in the Company for the purpose of protecting user’s rights during the procession of his personal data, including the user’s privacy rights.

The User of the website has to familiarize with the Policy when registering a request for entering into partnership with NDA LLC on the website and creating an account. The User provides his consent on personal data procession under art 9 №152-FZ.

Limited liability company “National Digital Aggregator” (PSRN 1157746188456, TIN 7709451253), that established in accordance with legislation of Russian Federation and with registration place: 109029, Moscow, Bolshaya Kalitnikovskaya street, house 42, office 316/1, is the Personal Data Processing Operator.

Personal information of the User

1.1. The Personal information of the User under this Policy refers to:
1.1.1. Personal data which User provides by his own will and in his own interest when applying the request for entering into partnership with NDA LLC and registering (creating) an account on website and also while using the website.

Personal information of the User (personal data), which Company proceeds when dealing with User’s applications:

• phone number of the User;
• passport data of the User;
• е-mail of the User;
• social network data of the User.

1.1.2 Data which transmitted automatically in the using of the Company’s website including cookie files, information about User’s device. Detailed terms of cookie files proceedings specified in the Policy of Cookies proceeding (Appendix No 1 to this Policy).

1.2. This Policy applies to relations between User of the Company’s site and the Company. Company accepts no responsibility or liability for proceeding of user’s personal data by third parties whose websites or other digital resources accessible via a link to the User on the website. User’s data on that occasion shall be proceeded by these third parties under their terms.

1.3. The Company is guided by the User’s integrity (the User provides correct data to the Company) when proceeding personal data. If its necessity of personal data actualization, the User shall request the Company by sending the request to the Company’s address or (and) by email of the Company policy@maggregator.com. Company shall alter information about the user and notify the user in thirty (30) days from the date of User’s request in a manner that User determined in the request.

1.4. Before the start of using the website and registration om website, the User provides consent to the procession of personal data specified in para 1.1.1. of this Policy which includes following means of processing: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), blocking, deletion, destruction of personal data.

1.5. Consent to the procession of personal data is provided to the necessary term for the achieving the purposes specified in para 2.1 of this Policy within the legislative restrictions. After expiration of the following term or after withholding of User’s consent, personal data of the User shall be destroyed.

1.6. Company does not collect data for the purpose of creation “User’s portrait” to the extent that may significantly affect on User’s rights and freedom and also doesn’t collect the information that belongs to the special category of personal data under FZ№ 152.

1.7. The User confirms that provided data to the Company does not apply to other subjects of personal data, in case of providing data of other subjects, including uploading such data through the personal account of the User. The User undertakes to obtain from such subjects of personal data the necessary forms of consent in accordance with the current legislation for their transfer to the Company, as well as provide electronic copies of these consents within 3 (three) days from the date of their submission to the Company.

Purposes of data collection and procession of Personal information of the Users

2.1. Procession of User’s personal data is carried out for the provision of services on the website of the Company, precisely for the purposes:

• receiving and review applications for entering into partnership with NDA LLC via application form on website
• creation of User’s account for the access to personalized services of the Company;
• authorization (identification) of the User;
• entering into and/or performance of the contacts between User and the Company
• provide the feedback with the User, including notifications, requests, processing of User’s applications and requests;
• quality improvement of the Company’s services and website;
• providing client support to the User;
• improvement and greater stability of the website, it’s usability and also creation of new services by getting feedback from users about current services;
• providing information to the User about evets and activities of Company in accordance with para 1 art 18 of Federal law of Russia “On advertising” of 13.03.2006 № 38-FZ;
• conducting statistical researches based on User’s personal data;
• marketing and promotion of Company’s services by direct contacts with potential clients by electronic means of communication;
• provision of other information directly related to fulfillment of Company’s obligations under the User agreement and this Policy.

Terms of User’s personal information procession and data transmission to third parties.

3.1. Security and confidentiality of personal data processed by Company are provided by technical, legal and organizational measures, required by federal legislation on personal data and applicable international standards.

The Company produced and implemented the internal regulatory documents for personal data protection which approves the requirements for the organization of measures aimed at User’s personal data protection.

3.2. The Company provides confidentiality of personal information and legal and technical measures from unauthorized access to the information, from occasional or illegal destruction, loss, misuse, disclosure and other illegal ways of data procession.

3.3. The Company does not transfer personal data of subjects to third parties and does not distribute publicly available personal data of subjects.

3.4. For Users – citizens of Russia, Company processes their personal data, including storage, involving the use of databases located in the territory of the Russian Federation. If applicable, the processing of personal data and protection of personal data of foreign citizens carried out in accordance with the applicable laws of foreign countries.

Altering of Privacy policy

4.1. Company may change the provisions of this Policy. The Company specify the date of the most recent update in current version of the Policy when changes the document. New version of the Policy will come into force from the date of its placement on website of the Company: https://zvonkodigital.ru/privacy-policy/ unless otherwise stipulated by the new version of the Policy.

Questions and suggestions

Questions and suggestions about this Policy, the User may send to support department by email of the Company info@zvonkodigital.com

Cookies policy

This Cookies policy (далее – Политика Cookie) has been drawn up regarding to cookie files used on the website of the website of the Company zvonkodigital.ru (hereinafter – the site)

The User approves his consent and familiarization with all terms of this Policy by accepting the Policy

The User confirms his consent on the procession of information when he visits any of Company’s website pages.

What are cookies?

Cookies are small text files or fragments of information created by the website, which are stored on User’s computer or on User’s device through website.

After web browser stored files, information about this may be sent back to the website, when web browser authenticates the User through opening the page of the website.

Types of cookies

Temporary (sessional): shall be deleted after the User closes his browser.

Constant: shall be stored in the device memory till the moment when User will delete them or till the expiration date of their storage.

Purposes of cookies usage

The Company uses cookies for:

• simplification and improving the effectiveness of website in response to Users’ preferences
• obtain the information about how the User had stumbled on the site (for example via link on the website of partners of the Company). The information can be sent from the website to web browser and vice versa.
• collecting the statistics protection Users against the fraud and detection of the fraud and protection against other threats.

How to prevent the User from using cookies (delete cookies)

Most of web browsers are configured to use coolies. The User is able to change the browser settings and change the settings before the receiving a notification of sending and receiving the cookies. The User can block the use of cookies by web browser in full.

The Company drew attention on the User’s prohibition of using cookies may cause a failure the process of using the website, lower productivity and limitation of its functions. That’s why the Company recommends to use the cookies with settings by choice of the User.









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