1. General Provisions This personal data processing policy is drawn up in accordance with the requirements of the Personal Data Law and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Uni-Crypt (hereinafter referred to as the Operator).
1.1. The Operator considers it its most important goal and condition of carrying out its activities to observe the rights and freedoms of a person and citizen when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can obtain about visitors to the website https://uni-crypt.com/ .
2. Basic Concepts Used in the Policy.
2.1. Automated processing of personal data – processing of personal data using computer technology.
2.2. Blocking of personal data – temporary cessation of processing of personal data (except for cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://uni-crypt.com/ .
2.4. Information system of personal data – a set of personal data contained in databases and information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data – actions as a result of which it is impossible to determine, without additional information, the affiliation of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity or individual who independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://uni-crypt.com/ .
2.9. Personal data permitted by the subject of personal data for dissemination – personal data, access to which is provided by the subject of personal data to an unlimited number of persons by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as personal data permitted for dissemination).
2.10. User – any visitor to the website https://uni-crypt.com/ .
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including public disclosure of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data – any actions as a result of which personal data are destroyed irretrievably with the impossibility of further restoration of the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right:
- to receive from the subject of personal data reliable information and/or documents containing personal data;
- in case the subject of personal data withdraws consent to the processing of personal data, as well as upon receipt of a request to cease the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
- independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Personal Data Law and regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obliged to:
- provide the subject of personal data, at their request, with information concerning the processing of their personal data;
- organize the processing of personal data in the order established by the current legislation of the Russian Federation;
- respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
- inform the authorized body for the protection of the rights of subjects of personal data upon request of this body of the necessary information within 10 days from the date of receipt of such a request;
- publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data;
- take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions with regard to personal data;
- cease the transfer (dissemination, provision, access) of personal data, cease processing and destroy personal data in the order and cases provided for by the Personal Data Law;
- perform other duties provided for by the Personal Data Law.
- Basic Rights and Obligations of Subjects of Personal Data
4.1. Subjects of personal data have the right:
- to receive information concerning the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data related to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law;
- to demand from the operator the clarification of their personal data, their blocking or destruction in the event that the personal data are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing, as well as to take legally provided measures to protect their rights;
- to impose a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
- to withdraw consent to the processing of personal data, as well as to send a request to cease the processing of personal data;
- to appeal to the authorized body for the protection of the rights of subjects of personal data or in court against illegal actions or inaction of the Operator when processing their personal data;
4.2. Subjects of personal data are obliged to:
- provide the Operator with reliable data about themselves;
- notify the Operator of the clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with false information about themselves, or information about another subject of personal data without the latter’s consent, bear responsibility in accordance with the legislation of the Russian Federation.
5. Principles of Processing Personal Data
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Combining databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed. 5.4. Only personal data that meet the purposes of their processing are subject to processing. 5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessiveness of processed personal data in relation to the stated purposes of their processing is not allowed. 5.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, their relevance in relation to the purposes of processing personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption for the removal or clarification of incomplete or inaccurate data.
5.7. Personal data are stored in a form that allows identifying the subject of personal data no longer than is required by the purposes of processing personal data, if the period of storage of personal data is not established by federal law, contract, a party to which, beneficiary or guarantor of which is the subject of personal data. Processed personal data are destroyed or depersonalized upon achieving the purposes of processing or in the event of the loss of the need to achieve these purposes, unless otherwise provided by federal law.
6. Purposes of Processing Personal Data Purpose of processing: Providing the User with access to services, information and/or materials contained on the website. Personal data: Last name, first name, patronymic, phone numbers, card or account details. Legal basis: Federal Law “On Information, Information Technologies, and Protection of Information” dated 27.07.2006 No. 149-FZ. Types of processing of personal data: Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data.
7. Conditions for Processing Personal Data
7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, to carry out the functions, powers, and obligations imposed on the operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, execution of a judicial act, act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the execution of a contract, a party to which or a beneficiary or guarantor under which is the subject of personal data, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary to realize the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data.
7.6. The processing of personal data, access to which has been granted by the subject of personal data to an unlimited number of persons or at their request (hereinafter referred to as publicly available personal data), is carried out.
7.7. The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for the Collection, Storage, Transfer, and Other Types of Processing of Personal Data The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the preservation of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
8.2. The personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the execution of current legislation or in the case where the subject of personal data has given consent to the Operator to transfer data to a third party for the performance of obligations under a civil law contract.
8.3. In the event of inaccuracies in personal data being identified, the User may update them independently by sending a notification to the Operator’s official Telegram account https://t.me/UniCrypt_AS with the note “Updating personal data.”
8.4. The duration of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless otherwise specified by contract or current legislation. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator’s official Telegram account https://t.me/UniCrypt_AS with the note “Withdrawal of consent to the processing of personal data.”
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those entities (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or with the aforementioned documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions on the transfer (except for granting access), as well as on the processing or conditions of processing (except for gaining access) of personal data permitted for dissemination, established by the subject of personal data, do not apply in cases of processing personal data in state, public, and other public interests as defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form that allows identifying the subject of personal data no longer than is required by the purposes of processing personal data, if the period of storage of personal data is not established by federal law, contract, a party to which, beneficiary or guarantor of which is the subject of personal data.
8.9. The cessation of personal data processing may occur upon achieving the purposes of personal data processing, expiration of the validity period of the subject’s consent to personal data processing, withdrawal of consent by the subject of personal data or a request to cease personal data processing, as well as the detection of unlawful personal data processing.
9. List of Actions Performed by the Operator with Obtained Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or without such.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border personal data transfer activities, the Operator must notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross-border personal data transfer (such notification is submitted separately from the notification of the intention to carry out personal data processing).
10.2. Before submitting the aforementioned notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, foreign legal entities to whom cross-border personal data transfer is planned.
11. Confidentiality of Personal Data The Operator and other persons who have gained access to personal data are obliged not to disclose third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via messengers https://t.me/UniCrypt_AS .
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://uni-crypt.com/privacy/ .