PRIVACY AND COOKIE POLICY
Your privacy is important to us. This privacy statement explains:
1. What personal data is collected by the owner of this web site or provided by you, through our interactions with you and your use of our web site (simkomat.com), apps and software
2. How your personal data will be used, where it is held, how long it will be kept and your rights.
Please read this privacy policy carefully.
1. DEFINITIONS AND INTERPRETATION
In this privacy, the following definitions are used:
Data controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
Data processor, in relation to personal data, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.
“You”, “your” or “data subject” means:
- Visitors to our website
- Subscribers to any service we offer through our site
-Users of our applications
- Prospective or existing clients corresponding with us by phone, e-mail or otherwise.
Data controller, “we”, “us” and “our” means:
LLC «Terminal solutions», its subsidiaries and its data processors;
Personal data means any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.
This definition provides for a wide range of personal identifiers to constitute personal data, including name, identification number, location data or online identifier, reflecting changes in technology and the way organisations collect information about people. The definition incorporates, where applicable, the definitions provided in General Data Protection Regulation.
2. CHANGES TO THIS PRIVACY POLICY
We reserve the right to update this Privacy Policy from time to time. Please review this policy periodically for changes. If you do not accept the amended Policy, please stop using this Website.
Who we are (Identity of the data controller)
LLC «Terminal solutions», with its registered address at Karl Marx Lane, 421, office 1, Izhevsk, Russian Federation, doing business as simkomat.com, its affiliates, subsidiaries data processors collectively referred to as simkomat.com.
3. PERSONAL DATA WE MAY COLLECT FROM YOU
We may collect and process the following data and personal information about you.
3.1 Personal Data you provide us voluntarily
We collect the information provided by you to operate effectively and provide you the best experiences with our Website, products and services. You provide some of this information voluntarily by filling in the contact forms on our website, creating an account at our Website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide if you subscribe to any service we offer through our site, send us a query or feedback, sign up for information on events, upload a document with your enquiry, participate in discussion boards or other social media functions on our site, promotion or survey, or when you report a problem with our Website.
This information may include your:
First name, Surname, e-mail address, phone number.
3.2 Children
We do not sell any products or services for purchase by children. If you are under 16, you may use our Website only with the involvement of your holder of parental responsibility. We do not knowingly collect personal information from children below 16 without the consent of the child's holder of parental responsibility.
3.3 Information you provide about others
In providing personal data about other individuals (such as someone in whose name you are registering an account or subscribing to our marketing promotions), you represent that you have notified them of (i) the purposes for which information will be used (ii) the recipients of their personal data and (iii) how they can access and correct the information. You further represent that You have obtained all necessary consents from them.
The data processing practices related to cases when we act as a data processor and process on behalf of our customers are described in our Data Processing Agreement and are not described this privacy policy.
4. INFORMATION WHICH MAY BE MADE AVAILABLE TO US OR COLLECTED AUTOMATICALLY WITH THE USE OF COOKIES OR ANALYTIC TOOLS
We might get some information from our visitors by recording how they interact with our Website with the use of cookies, analytics tools or obtain data from third parties.
5. TECHNICAL INFORMATION, INCLUDING PERSONALLY IDENTIFIABLE INFORMATION
Might include your device and connectivity information such as IP (Internet Protocol) address, unique device identifiers (such as the IMEI for phones)
6. NON-PERSONALLY IDENTIFIABLE INFORMATION
Might include your configuration data such as browser type, version and language setting, time zone setting, browser plug-in types and versions.
Details of how you used our Website, such as your search queries. Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Log information, such as error reports, download errors, any problems you experience using our website and any phone number used to call our customer service number.
We do not match information collected automatically through cookies and analytics tools with other personally identifiable information you may have provided to us when you registered for our Products or submitted a form through our Website.
7. COOKIE POLICY
A cookie is a small file, typically of letters and numbers, downloaded on to a device when the user accesses certain websites. Cookies allow a website to recognise a user’s device.
Why does simkomat.com use cookies?
Cookies allow us to improve the website's content, functionality and speed, while their tracking ability also helps us to understand your likes and dislikes, which means we can respond quickly and adapt the site accordingly.
We might use cookies to recognize you when you visit our site or use our Services, remember your preferences, and give you a personalized experience:
Authentication cookies. If you're signed in to our Services, these cookies will help us show you the right information and personalize your experience.
Session cookies. These cookies store the ID of a user’s session. The cookie is set when a user signs in and is used to restore the session without entering the personal data.
Security cookies. We use cookies for our security features, and to help us detect malicious activity.
Preferences, features and services. These cookies help us to customise your preferences, such as which language you prefer and what your communications preferences are or to fill out forms on our faster.
Performance, Analytics and Research. These cookies help us to analyse our web site performance. We use cookies to improve our products, features, and services, including to create logs and record when you access our site.
Third-party cookies. In order to improve the Website and the services we offer you, we may use (temporary and persistent) cookies, authorized third party cookies and/or other technologies to collect non-personally identifiable data. This non-personally identifiable data helps us to track browsing behavior, to create specific or tailor-made offers or advertisements, and to monitor and record the visits and use of the Website.
What can you do if you don't want cookies to be set or want them to be removed.
Most browsers accept cookies automatically, however some people prefer not to allow cookies. You may change the security settings of your web browser in order to stop your device receiving and storing cookies, to allow receiving and storing cookies from selected websites you trust, or to be notified before receiving cookies. You may also delete cookies stored in your browser at any time. Information stored in such cookies will be removed from your device. However, that these settings may have negative effects on the web sites usability.
Browser manufacturers usually provide help pages relating to cookie management in their products. Please see below for more information:
Google: support.google.com/chrome/answer/95647
Internet Explorer: support.microsoft.com/en-us/help/260971/description-of-cookies
Mozilla Firefox: support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
Safari (Desktop): support.apple.com/kb/PH5042
Safari (Mobile): support.apple.com/en-us/HT201265
Android Browser: support.google.com/nexus/answer/54068
Opera: opera.com/help
Opera Mobile: opera.com/help/mobile/android
For other browsers, please consult the documentation that your browser manufacturer provides.
You may opt-out of third party cookies from Google Analytics on its website.
You can opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (youradchoices.com). In addition, on your iPhone, iPad or Android, you can change your device settings to control whether you see online interest-based ads.
7.1 Information we might obtain from third parties
We might insert advertising on our partner websites, social networks or Advertising networks who might categorize website visitors with similar characteristics or interests into non-personally identifiable data segments and offer these segments to their own clients, visitors and subscribers. For example, if a person expresses an interest in cryptocurrency or beauty products, they might see an advertising banner linking to similar service provider company website.
We might obtain and record information that an ad was requested or shown, how many times, the target geography of the ad (which will not include an IP address or specific personally identifiable location and any user interactions with the ad or the page where the ad appears. This information is used for analysis, reporting and troubleshooting.
We do not perform any visitors profiling activities.
7.2 Where Do We Store Your Information?
We take Client confidentiality and security very seriously. We are committed to protecting the Personal Data you share with us. We use a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure.
The data processing consisting in hosting provider services (storage and maintenance of databases containing your personal data, protected by password) is performed on our behalf under written confidentiality agreements inside European Union Area.
The written agreements with the data processor guarantees that the requirements of the GDPR will be met and the rights of data subjects are protected. The Data Processor will only act on behalf of our documented instructions, have direct responsibilities under the GDPR and may be subject to fines or other sanctions if they don’t comply.
Once this contract is concluded, data processor will return data to us or transmit to another processor appointed by us, and erase any copy in its possession. However, the processor may keep the data locked to address possible administrative or jurisdictional responsibilities.
8. DATA RETENTION
We will keep your personal data During the performance of an oral or written contract between you and us or during the communication process related to the steps prior to entering a prospective verbal or written contract.
We may continue to retain such Personal Information even after the contract between parties terminates, as reasonably necessary to comply with our legal obligations or to protect our legitimate interests if applicable (Please see paragraph “Lawful basis and the purposes of the processing (Uses made of your personal information)”). We will use reasonable endeavours to ensure your data is up-to-date. As a data subject you have rights related to maintenance, storage and processing of your personal data. Please see paragraph “Your rights”.
Unless otherwise specified, where you have indicated to us that you are happy for us to send you the information about the services we offer and we feel may interest you or similar to those that you have already purchased or enquired about do so, we assume you are happy for us to keep your collected personal data. We may retain your Personal Information (contact details) for as long as your User Account is active or as otherwise needed to provide you with information our Services. As the data subject you have rights related to processing of your personal data and the option of withdrawing your consent to receive promotions at any time. Please see paragraph “Your rights”.
9. LAWFUL BASIS AND THE USES MADE OF YOUR PERSONAL INFORMATION
We process all personal data lawfully, fairly and in a transparent manner. We use the data we collect for the following basic purposes, described in more detail below.
9.1 To take steps at the request of the data subject prior to entering into a business relationship (oral or written contract)
By contacting us by means specified in paragraph “Personal Data you provide us voluntarily” we assume that processing is necessary for the performance of a business relationship (oral or written contract) or in order to take steps prior to entering into a business relationship (oral or written contract), and therefore the lawful basis is Contract and our Legitimate interests.
We will use the provided information to operate effectively and do our best to respond to your enquiry. Once you enter into a business relationship (oral or written contract) with us, we will invoice our services and offer you post-sales service and loyalty if required.
9.2 Holding information
We might hold your information for as long as is necessary to comply with our and legal obligations and in accordance with our legitimate interests as a data controller after the contractual relationship between you and us elapses. The lawful basis for such retention is Legitimate interests and Legal obligation. As the data subject you have rights related to maintenance, storage and processing of your personal data. Please see paragraph “Your rights”.
9.3 Communication
To send you communications, including promotional communications and advertising with your explicit consent or allow you to participate in interactive features of our service, when you choose to do so. The lawful basis for such processing is Consent.
If you wish not to receive such promotional emails, you may withdraw your consent at any time by contacting us as described in paragraph “Your rights” or follow the “unsubscribe” or instructions contained in the promotional communications you receive.
9.4 Website improvement
We might use your automatically collected data such as IP address and browser data for our Website improvement, such as:
To administer our site and for internal operations, including data security, troubleshooting, testing, statistical and survey purposes;
To ensure that content from our site is presented in the most effective manner for you and for your device. The lawful basis for such processing is Legitimate interests.
10. DISCLOSURE OF INFORMATION TO THIRD PARTIES
We do not rent, sell, or share personal information about you with other people or non-affiliated companies without your consent except to provide products or services you've requested, when we have your permission, or under the following circumstances:
1. We may disclose your information to third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person.
2. In the event we are acquired by or merged with a third party entity or undergo another change of control, we reserve the right to transfer information, including any PII and non-PII, to a successor entity. In this event, we will notify you by electronic means before information about you is transferred and becomes subject to a different privacy policy.
11. LAW ENFORCEMENT, LEGAL REQUESTS AND DUTIES
We may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you. Your details may also be disclosed to the police and law enforcement agencies for the purpose of fraud detection, crime prevention and national security.
12. YOUR RIGHT
You have the following rights in accordance with the General Data Protection Regulation:
The right to be informed. In this privacy statement we supply you detailed information related to your personal data storage, maintenance and processing.
The right to access information held about you.
The right to rectify your personal data if it is inaccurate, incomplete or out-of-date.
The right to erasure (delete or remove) your personal data.
The right to restrict (block) processing. When processing is restricted, we will store your personal data, but not further process it.
The right to data portability which allows individuals to obtain and reuse their personal data for their own purposes across different services. It allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.
Rights related to automated decision making including profiling.
We are not making any decisions which might produce a legal effect on you based on automated processing.
The right to withdraw your consent (object) to direct marketing.
You can exercise your rights by contacting us at [email protected]
The right to lodge a complaint with a supervisory authority.
You have The right to lodge a complaint with your local supervisory authority if you have a concern about our information rights practices.
