WEBSITE AND MOBILE APPLICATION
PRIVACY POLICY
1. DEFINITIONS
Law means the Federal Law of the Russian Federation "On Personal Data" with all amendments and additions, as well as other legislative acts of the Russian Federation.
Website means an information unit on the Internet, a resource made up of web pages (documents) that are united by a common theme and linked to each other through links. It is registered in the Copyright Holder's name and is necessarily linked to a specific domain, which is his address. The Policy has been developed for the following websites: sign.me; event.sign.me.
Mobile Application means the CIPF "Sign.me "Execution-1" Electronic Signature System", designed to work on mobile devices (smartphones) and tablets, developed by the Copyright Holder for mobile devices and tablets with the iOS and Android operating systems and mandatory for installation by the User in order to be able to use the Copyright Holder's Mobile Application.
Personal Data means a set of personal data and/or non-personal data about the User provided by the User to the Copyright Holder and/or automatically collected by the Copyright Holder and/or third parties.
Policy means this Website and Mobile Application Privacy Policy (with all existing additions and amendments).
User means a legal entity or individual who uses the Website and/or Mobile Application and/or has access to them from any device.
Terms of Use means an agreement concluded between the Copyright Holder and the User regarding the procedure, rules and features of the use of the Website and Mobile Application. The User subscribes to such an agreement and has no right to make and/or require any amendments or additions to it. The User can read the terms of the Terms of Use via the following link: https://sign.me/static/oferta.pdf .
Copyright Holder means the following person in whose name the Website is registered and who is the copyright holder of the Mobile Application:
LLC “SM”
Address: 45 Michurinskiy Ave., Room 40, Floor 2, Moscow
OGRN (Primary State Registration Number): 1117746908597
INN (Taxpayer Identification Number): 7719795020
KPP (Tax Registration Reason Code): 772901001
Cookies means small files sent by a website and placed on the User's computers, smartphones, tablets, watches and other mobile devices to improve the operation of the websites, as well as the quality of the content posted on them.
2. RELATIONSHIPS COVERED BY THE POLICY
General provisions
The Policy shall be used and applied exclusively to the Personal Data received from the User in connection with their use of the Website and Mobile Application. The provisions of this Policy are aimed at:
(1) determination of the types of the Personal Data received, directions and purposes of the Personal Data use (processing), as well as the sources of obtaining such Personal Data; and
(2) definition of the User's rights in relation to the protection of the confidentiality of the Personal Data transmitted by him; and
(3) identification of persons responsible for the processing and storage of the Personal Data, as well as third parties to whom such data is disclosed (in whole or in part).
The rules of the Policy shall not apply in the case of processing of the Personal Data that is voluntarily provided by the User by third parties.
By using the Website and/or Mobile Application, the User agrees to the terms of the Policy and gives his consent to the Copyright Holder to collect, process, retain and store the Personal Data in accordance with the procedure and conditions provided for in the Policy.
If the User does not agree with the terms of the Policy and/or does not understand certain terms of the Policy, the User must immediately stop using the Website and/or Mobile Application.
User's Rights to the Personal Data Protection
In connection with the provision of the Personal Data, the User shall automatically receive the following rights:
(1) to receive data related to it processing (the grounds and purposes of such processing, the processing methods used, information about persons who have access to it or to whom it may be disclosed on the basis of the agreement or Law).
(2) to receive data on the location and identification of persons processing the Personal Data.
(3) to receive data on the terms of storage of the Personal Data.
(4) to receive data on the transfer of the Personal Data that has been transferred or is expected to be transferred across the border.
(5) to appeal the actions or omissions of the Copyright Holder to the authorized body for the protection of the rights of personal data subjects or to court.
(6) to receive compensation for damages and/or compensation for moral damage in court as a result of violations of the User's rights to the protection of his Personal Data committed by the Copyright Holder and/or third parties.
(7) to exercise other rights in the field of personal data protection provided for by Law or the provisions of the Policy.
3. LIST OF THE PERSONAL DATA COLLECTED
Non-personal User data
In connection with the use of the Website, the Copyright Holder may automatically collect and process the following non-personal data about the User:
(1) traffic information, possible number of clicks, logs and other data.
(2) data about the device (identification number of the device from which you log in, operating system, platform, browser type and other information about the browser, IP address).
User Personal Data
The User provides the Copyright Holder with the following Personal Data about himself:
(1) full surname, name and patronymic.
(2) date of birth and age.
(3) address of the place of permanent residence.
(4) email address.
(5) mobile phone number.
(6) User's sex.
(7) User's nationality.
(8) data contained in the User's personal account (profile), all internal correspondence of the User (if any), as well as other activity of the User's personal account (profile).
(9) data on the orders made by the Users and/or services received/paid for through the Website and/or Mobile Application.
(10) the following data:
SNILS (Individual Insurance Account Number) and INN
(11) data and information obtained as a result of combining certain Personal Data of a particular User, as well as data and information received from third parties (partners, marketers, researchers).
(12) the Users shall also consent to the provision of contact list data contained on the User's mobile device on which the Mobile Application is installed and used. Since, technically, sending an electronic document for signing through the Mobile Application is possible only to a person whose mobile phone is included in the User's contact list, the specified provision of the contact list by the User of the Mobile Application shall be performed solely for the purpose of correct operation of the Mobile Application and the possibility of full implementation of its functionality. The Copyright Holder shall not collect and process personal data of persons contained in the User's contact list, but only use access to the User's contact list through a Mobile Application to be able to sign electronic documents.
The received contact data shall be sent to the application server via a special software interface (API) via the appropriate communication channel. The application server then shall compare the received contacts with user data in the company's database to determine if there are any registered users among them. After that, information about registered users shall be sent back to the application so that the User can see which of his contacts are already using the Application. At each stage of this process, the security and confidentiality of User data is ensured, and this data is in no way used for commercial or marketing purposes.
After the User's contact data has been sent to the Application server and the comparison with registered Users has been made, this data shall be immediately deleted and no longer used. No information about the User's contacts is saved anywhere. This is done to ensure maximum privacy and security of User's data.
The User shall be the only person responsible for the completeness of the Personal Data provided and shall carry out timely amendments (updating, verification, correction) on a regular basis.
The Copyright Holder assumes that all the Personal Data provided by the User is reliable and that the User maintains such information up to date.
Use of Cookies
The Website uses certain Cookies to store the IP address, User preferences, or type of device used for the purpose of (1) maintaining statistics on Website visits and traffic, and (2) personalization of the data displayed on the User's screen, and (3) storing the data necessary to identify the User, including when accessing from different devices, and (4) displaying ads in accordance with the interests and preferences of the User. The Website can use both its own Cookies belonging to the Copyright Holder and Cookies of third parties.
The Website uses the following Cookies:
(1) Technical (functional) Cookies, which are necessary to control traffic and data transmission, to identify the Users and provide access to content to the User, and without which the use of the Website is functionally limited, as well as to prevent the provision of recommendations that do not correspond to the interests of the User.
(2) Statistical Cookies, which are needed to track the frequency of the User's visits to the Website, to identify how the Website is used, as well as to identify the type of content that is popular or interesting to the User.
(3) Third-Party Cookies, which are installed by third parties with the User's permission and are intended for conducting statistical research concerning the User's behavior on the Internet and/or sending personalized advertising or marketing materials to the User and/or providing goods or services.
The User shall have the right to disable Cookies at any time by changing certain browser settings. Such actions may result in a restriction or modification of the User's access to the functionality of the Website and/or its content.
4. PERSONAL DATA COLLECTION AND PROCESSING PURPOSES
Defining processing goals
The Personal Data collection and processing shall be carried out for the following purposes:
(1) to analyze User's behavior, as well as to identify User's preferences for a certain type of content.
(2) to ensure prompt and correct operation of the Website, improve its functionality and content.
(3) to identify the User.
(4) to comply with the requirements of the Law.
(5) to track orders made by the User through the Website and/or Mobile Application.
(6) to provide technical support for the Website and/or Mobile Application, identify problems in operation and eliminate them.
(7) to keep in touch with the User (communication).
(8) to fulfill other obligations of the Copyright Holder that have arisen before the User.
(9) to conduct statistical research.
(10) for any other purposes (subject to obtaining separate consent from the User).
The Personal Data processing shall be carried out on the basis of the following principles: (1) the legality of the purposes and methods of processing; and (2) good faith; and (3) compliance of the purposes of the Personal Data processing with the purposes previously defined and declared when collecting such Personal Data; and (4) compliance of the volume and nature of the processed Personal Data with the stated purposes of its processing.
Terms of Personal Data processing
The Personal Data processing shall be carried out in the following cases: (1) upon obtaining consent from the User; or (2) upon achievement by the Copyright Holder of the objectives provided for by an international agreement or Law; or (3) upon provision by the User of their Personal Data to an unlimited number of people; or (4) upon fulfillment of other obligations of the Copyright Holder to the User, including, but not limited to, provision of certain content to the User; or (5) for saving the User's life or health when consent to the processing of his Personal Data cannot be obtained in advance.
In the case of depersonalization of the Personal Data, which does not directly or indirectly identify the User, the subsequent use and disclosure of such data to third parties shall be allowed and the rules of the Policy shall no longer apply to it.
The Copyright Holder shall take all possible measures to protect the confidentiality of the Personal Data received, except in cases where the User has made such data publicly available.
The processing of the Personal Data shall be carried out with and without the use of automation tools.
5. ACCESS TO THE PERSONAL DATA BY THIRD PARTIES
Use of analytical platforms
The Copyright Holder uses the Rating Mail, VK ADS and Yandex.Metrika analytical platforms for (1) tracking the frequency of the User's visits to the Website; and (2) tracking the User's use of the Website and/or its content; and (3) identifying the type of content that is popular among the Users; and (4) determining the User's location. The User also gives his consent to the Copyright Holder to use the data about the User received from Rating Mail, VK ADS and Yandex.Metrika.
For these purposes, the Rating Mail, VK ADS and Yandex.Metrika analytical platforms may collect data about the IP address, geolocation, User behavior, as well as their preferences and interests in relation to certain content.
The Rating Mail, VK ADS and Yandex.Metrika analytical platforms shall gain access to the Personal Data in order to provide the Copyright Holder with an understanding of how effectively his Website works, what kind of content is popular, how effective is the placement of a particular advertisement, as well as for the purpose of developing and/or improving the existing marketing strategy of the Copyright Holder.
From the moment of using the Website, the User agrees to the privacy policy of Rating Mail, privacy politicy of VK ADS, and the privacy policy of Yandex.Metrika, as well as the automatic installation of appropriate Cookies on the User's device.
Disclosure of the Personal Data to third parties
The Copyright Holder shall have the right to disclose the Personal Data to (1) its affiliates, branches and representative offices opened both on the territory of the Russian Federation and on the territory of other states;(2) the legal successors of the Copyright Holder who arose as a result of its liquidation, reorganization or bankruptcy, and who received exclusive ownership rights to the Website;
(3) third parties, solely for the purpose of providing the User with certain content or access to it; (4) third parties, when the User has given consent to the disclosure, transfer or processing of their Personal Data, as well as in other cases expressly provided for by the Law or the Policy.
The Copyright Holder shall disclose the Personal Data only if (1) he is confident that third parties will comply with the terms of the Policy and take the same measures to protect the confidentiality of the Personal Data that the Copyright Holder himself takes, and (2) the User had previously expressed his consent to such disclosure and/or it is permitted by the Law.
6. ADVERTISEMENT PLACEMENT
Advertisement on the Website
The Copyright Holder does not place advertisement on the Website.
7. SENDING COMPLAINTS AND REQUESTS TO THE COPYRIGHT HOLDER
Requirement to terminate the Personal Data processing
Each User shall have the right to express his objection to the Copyright Holder against the processing and/or storage of his Personal Data. Such an objection can be expressed as follows:
Request via the info@sign.me email address
Request for information about the Personal Data
If the User has questions related to the procedure for applying or using the Policy, the procedure and/or method of processing the Personal Data, the User can ask such a question as follows:
Request via the info@sign.me email address
Amendment (updating, addition, correction) or deletion of the Personal Data
The User shall have the right to independently amend or delete his Personal Data at any given time, except in cases where such an amendment or deletion may lead to (1) violation of the rules of the Policy; or (2) violation of the Law; or (3) the nature of such Personal Data is evidence in any legal processing that has arisen between the Copyright Holder and the User. To do this, the User needs to delete his personal account (profile) on the Website.
The Copyright Holder shall have the right to delete the User's personal account/profile, as well as all the Personal Data about the User at any given time, if the User has violated the terms of the Policy and/or the Terms of Use.
8. TERM AND PROCEDURE FOR PERSONAL DATA STORAGE
The storage shall be carried out independently by the Copyright Holder.
The storage shall be carried out during the entire period of use of the Website and/or Mobile Application by the User.
9. ACCESS OF MINORS TO THE WEBSITE
The use of the Website is intended for persons over the age of 18, who gain access to it only if they provide prior consent to the processing of their Personal Data. The Copyright Holder checks the User's age as follows:
Personal identification
If the User is a minor, then he must immediately stop using the Website.
10. PERSONAL DATA PROTECTION PROCEDURE
Protecting the confidentiality of Personal Data shall be the primary high priority task for the Copyright Holder. The Copyright Holder shall adhere to all required international standards, rules and recommendations for the Personal Data protection.
The Copyright Holder has implemented a number of technical and organizational methods aimed at protection of the Personal Data from disclosure or unauthorized access to it by third parties.
11. FINAL PROVISIONS
Accessibility of the Policy text for review
Users can read the terms of the Policy via the following link: https://sign.me/media/policy.pdf .
Policy amendment and supplementing
The Copyright Holder may unilaterally amend the Policy. The fact that the amended version of the Policy is published on the Copyright Holder's website shall be deemed a proper notification of the Users about the fact of making amendments to the Policy. The Copyright Holder shall not bear any responsibility to the User for amending the terms of this Policy without the User's permission and/or consent.
The User shall check the provisions of the Policy on a regular basis for possible amendments or additions.
Applicable law
The Policy has been developed in accordance with the current legislation on the personal data protection of the Russian Federation, in particular, with the norms of Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (with all additions and amendments), Federal Law No. 242-FZ dated July 21, 2014 "On Amendments to Certain Legislative Acts of the Russian Federation Regarding the Clarification of the Procedure for the Personal Data Processing in Information and Telecommunications Networks" (with all additions and amendments).