This Policy explains our procedure for processing Personal Data.
1.2 This Policy is issued by Ol_Nic (the “Operator”).
1.3 To reflect changes in our Personal Data Processing practices or changes in applicable law, this Policy may be amended and supplemented or updated. We recommend that you read this Policy carefully and check this page regularly to review any changes we may make to the terms of this Policy.
1.4 This Policy is intended for individuals outside of our organization with whom we interact, including individual customers, customer representatives, business partners and third parties, visitors to our Websites, users of our App, and other users of our services (collectively, “you”).
Collection of Personal Information
2.1 Generally, we will process Personal Information that we receive from you or collect from you when you purchase products, browse the Website, use the App, or interact with us directly. For example, we will collect or receive your Personal Information when
2.1.1. we collect or receive your Personal Information in the ordinary course of our relationship with you;
2.1.2. when you provide us with Personal Data directly (e.g. when you contact us by email, telephone or any other means of communication, provide your contact details or send us an application for employment);
2.1.3. we may collect information about a transaction, payment or related inquiries when receiving the Operator’s service.
2.1.4. we may collect contact information and information about your request that is necessary to fulfill or respond to your request when you contact us or send us questions, comments, suggestions or complaints;
2.1.5. we may collect contact and other information in order to review your resume when applying for a position;
2.1.6. We may collect information you use to create or access accounts when you create or access such accounts on our Websites or in the Application;
2.1.7. We may collect information about how you use our Websites and your location when you use (and install, where applicable) our Websites or the App;
2.1.8. We may collect Personal Information from the relevant third party content or advertising provider if you interact with such third party content or advertising on our Websites or App (including third party plug-ins and cookies);
2.1.9. we collect or receive Personal Information from third parties who provide it to us (such as credit reporting agencies, law enforcement agencies, etc.); and
2.1.10. We collect any other Personal Information that you voluntarily provide to us for any other reason.
2.2 We may also Process Personal Information that you explicitly share, including Personal Information that you share regarding the Group on social media platforms such as Facebook, Twitter, and Yandex.
2.3 In certain circumstances, we may also create Personal Information about you, such as records of your interactions with us and data about your past interactions with us. We may also aggregate Personal Information from our Websites, App, products or services, including when such information is collected from different devices.
2.4 Please also note that we may collect your Personal Information through the use of cookies (small data files stored on your device and used to access and use our Websites), web beacons (small, transparent images used to track website visits and advertising effectiveness) and other similar technologies.
2.5 Information collected through the use of such cookies and beacons is typically more technical in nature, such as IP addresses, browsers, and device types.
2.6 Although cookies and beacons are generally accepted automatically according to your browser settings, such settings can be adjusted or changed directly in your browser. However, please note that cookies and beacons may be required to access or use certain features of our Websites or App.
2.7 When you use a mobile device to access our Websites, we may also Process information about your physical location. You are not required to consent to the provision of such information and can opt out of our collection of such information by adjusting or changing the settings on your device.
Categories of Personal Information Processed
3.1 We may Process the following categories of Personal Information about you:
3.1.1 Personal information: name(s); preferred name; photographs.
3.1.2 Identifying information: national identification number or passport.
3.1.3 Contact information: address for correspondence; actual address of residence, telephone number; e-mail address; details of your public profile(s) in social networks.
3.1.4 Consent records: Records of consents you may have given, including the date and time, how you gave consent, and related information (e.g., subject of consent).
3.1.5 Data related to our Websites and Applications: Device type; operating system; browser type; browser settings; IP address; language settings; dates and times you connect to the Website; Application usage statistics; Application settings; dates and times you connect to the Application; other technical communication information; username; password; secure login information; usage data; summary statistics.
3.1.6 Content and Advertising Data: Records of your interactions with online advertisements and content, records of advertisements and content displayed to you on pages or screens of the App, and your possible interactions with such content or advertisements (including mouseover, mouse clicks, forms you fill out (including unsent incomplete forms), and any touch screen interaction).
Special Categories of Personal Information
4.1 We do not seek to collect or otherwise Process Special Categories of Personal Data in the ordinary course of business. If there is a need to Process Special Categories of your Personal Data for any reason, we may Process it under the following conditions:
4.1.1. compliance with applicable law: we may Process Special Categories of your Personal Data if such Processing is required or permitted by applicable law;
4.1.2. crime detection and prevention: we may Process Special Categories of your Personal Data if such Processing is necessary for the purpose of detecting or preventing crime (for example, fraud prevention);
4.1.3. establishing, enforcing or defending legal requirements: we may Process Special Categories of your Personal Data if such Processing is necessary for the purpose of establishing, enforcing or defending legal requirements; or
4.1.4. having consent: we may Process Special Categories of your Personal Data if, in accordance with applicable law, we have obtained your express consent prior to Processing Special Categories of your Personal Data (this legal basis applies only to fully voluntary Data Processing, it does not apply to Data Processing that is on any basis necessary or obligatory).
Data retention
6.1 We shall take all steps reasonably necessary to ensure that your Personal Data is only Processed for the minimum period necessary to achieve the purposes set out in this Policy. The criteria for determining the retention period for your Personal Data are as follows:
6.1.1. we will retain Personal Data in a form that allows us to identify its subjects, solely for as long as:
(A) we have an ongoing relationship with you (for example, as long as you use our services or are lawfully on our mailing list and have not unsubscribed); or
(B) your Personal Data is necessary for the legitimate purposes set out in this Policy for which we have a valid legal basis (for example, if your Personal Data is included in a contract between us and we need to continue to Process such Data to fulfill our obligations under that contract; if we have a legal obligation to retain your Personal Data);
6.1.2. within:
(C) the applicable statute of limitations period under applicable law (i.e., the period within which the relevant person may make a legal claim against us in connection with your Personal Data or to which your Personal Data relates); and
(D) two (2) additional months after the end of such applicable limitation period (so that we have a reasonably necessary period of time to identify the Personal Data relevant to the claim in the event that the relevant person makes such a claim at the end of the limitation period),
6.1.3. in addition, we shall continue to Process the Personal Data within the additional time periods required in connection with such a claim, in the event that the relevant person has made a legitimate claim.
6.2 During the time periods referred to in Sections 6.1.2(A) and 6.1.2(B) above, we will limit the Processing of your Personal Data to its storage and security, unless such data needs to be considered in connection with a legal requirement or obligation under applicable law.
6.3 Upon completion of the deadlines set forth in Sections 6.1.1, 6.1.2 and 6.1.3 above (each such deadline, as applicable), we:
6.3.1. permanently delete or destroy the relevant Personal Data; or
6.3.2. anonymize the relevant Personal Data.
Disclosure of Personal Data
7.1 We disclose Personal Data to other organizations within our group companies for legitimate business purposes and to operate our Website, App, provide you with our products or provide our services in accordance with applicable law. In addition, we disclose Personal Information to:
7.1.1. to you and (where applicable) your designated representatives;
to legislative or regulatory authorities at their request or for the purpose of reporting actual or suspected violations of applicable law or regulation;
7.1.2. accountants, auditors, consultants, lawyers and our other third party professional advisors, subject to contractual confidentiality obligations of a legally binding nature;
7.1.3. third-party Data Processors (e.g. payment service providers; IT service providers, etc.) located anywhere in the world;
7.1.4. to the relevant party, regulatory, governmental, law enforcement agency or court where such disclosure is necessary for the purpose of establishing, enforcing or defending legitimate claims;
7.1.5. to the relevant party, regulator, state, law enforcement agency or court for the purpose of prevention, investigation, detection, prosecution of criminal offenses or enforcement of criminal penalties;
7.1.6. to the relevant third party acquirer(s) or assignee(s) (including the potential third party acquirer(s) or assignee(s)) in the event we sell or transfer all or any portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
7.1.7. to an appropriate third party provider if third party advertising, plug-ins or content is used on our Websites and App. If you choose to interact with such advertisements, plug-ins or content, your Personal Information may be shared with the relevant third party provider. We recommend that you review such third party’s privacy policy prior to interacting with its advertisements, plug-ins, or content.
Protecting the Location of Personal Information
8.1 We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information and to reduce the risk of loss or theft, unauthorized access, disclosure, copying, misuse or alteration. We also periodically update and review such security measures. Please understand that despite the use of these security measures and our efforts, no system or network can be completely secure and that there are inherent risks in the disclosure of Personal Information via web browsers and electronic devices.
8.2 Since the Internet is an open system, the transmission of information through it is not completely secure. Although we will take all steps reasonably necessary to protect your Personal Information in the manner set out above, we cannot guarantee the security of your information transmitted to us over the Internet – any such transmission is at your own risk, and you are responsible for ensuring that all Personal Information you send to us is secure.
8.3 Because of the international nature of our business, we transfer Personal Information within our corporate group and to third parties as described above in connection with the purposes set forth in this Policy. In this regard, we transfer Personal Data to other countries which may have different data protection laws and requirements from the country in which you are located. We are required to transfer Personal Data processed under this Policy in accordance with applicable Data Protection Laws.
8.4 Please note that if you transfer your Personal Data directly to one of our organizations, we will not be liable for such transfer of your Personal Data. However, as soon as we receive your Personal Data, we will Process it in accordance with the provisions of this Policy.
Your Rights
9.1. Subject to applicable law, you may have the following rights with respect to our Processing of your relevant Personal Data:
9.1.1. the right not to provide us with your Personal Information (please note, however, that if you do not provide us with your Personal Information, we may not be able to provide you with all the benefits of using our Website, Application, products or services (for example, without the necessary data, we will not be able to process your requests));
9.1.2. the right to request access to your Personal Data or copies thereof, together with information regarding the nature of such Personal Data, its Processing and disclosure;
9.1.3. the right to request correction of inaccuracies in your Personal Data;
9.1.4. the right to request the deletion of your Personal Data on legitimate grounds or to restrict the Processing of your Personal Data;
9.1.5. the right to transmit certain Personal Data to another controller in a structured, commonly used and machine-readable format (if applicable);
9.1.6. when processing your Personal Data based on your consent, the right to withdraw such consent (it should be noted that such withdrawal shall not affect the legality of Processing carried out before the date we receive notice of such withdrawal and shall not preclude processing of your Personal Data on any other available legal grounds); and
9.1.7. the right to complain about the Processing of your Personal Data to the data protection supervisory authority.
9.2 Subject to applicable law, you have the following additional rights with respect to our Processing of your Personal Data:
9.2.1. the right to object (for reasons relating to your particular situation) to the Processing of your Personal Data by us or on our behalf; and
9.2.2. the right to object to the Processing of your Personal Data by us or on our behalf for direct marketing purposes.
9.3. These rights do not affect your statutory rights.
9.4 To exercise one or more of these rights, if you have any questions about such rights, about any other provision of this notice, or about our Processing of your Personal Data, please use the contact details set out in Section 10 below. Please note that:
9.4.1. in some cases, proof of your identity will be required before you can exercise such rights; and
9.4.2. if additional facts need to be established to fulfill your request (for example, to determine whether there is a non-compliance of the Data Processing procedure with applicable law), we will consider your request as soon as reasonably practicable before deciding on further action.
Contact Information
10.1 If changes need to be made to ensure that your Personal Information is accurate, complete and up-to-date, you may contact us or log in to your account (if applicable). You can also send us a written request if you would like access to your Personal Information collected by us. Please be advised that in order for you to modify, access, or review your Personal Information on your own, we may ask you to provide us with the necessary identification information.
10.2 In all cases, we will generally try to respond to your request within thirty (30) days or advise you of the need for an extension of time to respond.