Privacy policy
Last updated on 18 November, 2020
This Privacy Policy (hereinafter referred to as the “Privacy Policy”) of the Web3 Technology Limited Liability Company (hereinafter referred to as the “Company”) establishes the procedure for processing information which constitutes personal data that Website visitors and/or Software users (licensees) (hereinafter referred to as “Users”) provide to the Company.
By using the Website and/or the Software or by communication with the Company the User provides its unconditional consent to this Privacy Policy and the terms of processing of their personal data specified herein; in case of disagreement with these terms, the User must refrain from using the Website and communicating with the Company.
In accordance with the current legislation of the Russian Federation, the Company is the operator of personal data. The Company organizes and implements personal data processing in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” and other regulations adopted in accordance therewith.
1. Terms and Definitions
The following Terms and Definitions are used herein:
Personal data confidentiality refers to the obligation of the operator and other persons who have obtained access to personal data not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise stipulated for by the Federal law. License agreement refers to the license agreement available at https://we.vote/ Depersonalization of personal data refers to measures that make it impossible, without using additional information, to match personal data to a specific personal data subject.
Personal data processing refers to any action (operation) or a set of actions (operations) with personal data performed with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, correction (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
Company refers to Web3 Technology Limited Liability Company, registered address: 119072, Moscow, Bersenevskaya emb., 6, bldg. 3, fl. 4, suite I, room 9. The operator of personal data is the Company.
Personal data refers to any information related directly or indirectly to a specific or identifiable individual (personal data subject). Provision of personal data refers to actions aimed at personal data disclosure to a certain person or a certain group of persons. Software refers to Waves Enterprise E-Voting software registered in the Russian Federal Service for Intellectual Property (Rospatent) (Certificate No. 2020616306 of 15.06.2020), which is a set of activated and non-activated data and commands that implement the voting functionality on the basis of the WAVES ENTERPRISE Blockchain platform registered in Rospatent (Certificate No. 2019662198 of 18.09.2019) and entered in the Unified Register of Russian software and databases (based on the order of the Ministry of Communications of the Russian Federation dated 07.04.2020, No. 162).
Dissemination of personal data refers to any actions aimed at the disclosure of personal data to an indefinite number of persons. Website refers to https://we.vote/, including all its web pages.
Personal data subject (s) refers to an individual who can be identified, directly or indirectly, by reference to the personal data.
Destruction of personal data refers to actions that make it impossible to restore the content of personal data in the personal data information system and/or actions that destroy the material carriers of personal data.
2. General Provisions
2.1. Personal data processing in the Company is based on the following principles:
• The User’s personal data is processed in a legal and fair manner; • The processing of the User’s personal data is limited to the extent required for the achievement of specific, predefined and legitimate goals; • The content and volume of the User’s personal data processed correspond to the stated purposes of their processing; the processed personal data is not redundant in relation to the purposes of the processing thereof; • Databases with personal data that are processed for incompatible purposes shall not be merged; • Ensuring the accuracy of personal data, their sufficiency, and, if necessary, their relevance to the purposes of personal data processing; • Personal data in a form that allows for identifying the subject of personal data is stored no longer than required by the purposes of personal data processing unless the period of personal data storage is established by federal law, a contract to which the subject of personal data is a party, beneficiary or guarantor.
2.2. The User’s personal data is kept confidential.
2.3. The Company may transfer personal data to its affiliates in Russia. The term “affiliated entity” has the meaning specified in article 4 of the Law of the RSFSR of March 22, 1991. N 9481 “On Competition and Restriction of Monopolistic Activities on Product Markets”. The Company also has the right to disclose the User’s personal data to third parties in the following cases:
2.3.1. The disclosure is necessary to enable the User to use a certain service or to fulfill an agreement or contract with the User;
2.3.2. The transfer is provided for by the legislation of the Russian Federation or other applicable legislation within the framework of the procedure established by law;
2.3.3. Should the Website be sold, the buyer assumes all obligations to comply with the terms of this Privacy Policy in relation to the personal data received by them.
2.4. The User’s personal data is processed by any legal methods, including the use of personal data information systems based on automation tools or without the use of such tools.
2.5. Should personal data be lost or disclosed, the Company shall inform the User about the loss or disclosure of personal data. The Company, in cooperation with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data. 2.6. This Privacy Policy applies to all executives and employees of the Company (temporary and permanent), as well as to executives and employees of third-party organizations which have contractual relations with the Company and are involved in the Company’s activities related to personal data processing.
3. Purposes of Personal Data Collection
3.1. The Company processes the User’s personal data for the following purposes:
3.1.1. User identification;
3.1.2. enabling the User to use the Software in accordance with the License Agreement;
3.1.3. communication with the User, obtaining feedback from the User;
3.1.4. determining the User’s location to ensure security and prevent fraud;
3.1.5. providing the User with effective customer and technical support in case of problems related to the use of the Website;
3.1.6. performing advertising activities with the consent of the User.
4. Scope and Categories of Personal Data
4.1. The Company processes, with or without the use of automation, the following categories of personal data:
• the email address of the Account owner (within the meaning of this term defined in the License Agreement); • email addresses of the participants of voting conducted with the use of the Software.
When providing the Operator with the email addresses of third parties participating in voting conducted with the use of the Software, the Licensee hereunder guarantees to the Operator that the Licensee has received the appropriate permission and/or instruction from such voting participants to transfer their email addresses to the Operator for processing in accordance herewith.
4.2. The Company processes personal data of personal data subjects to the extent necessary to achieve the goals set.
4.3. The Company also processes the following User data:
• IP address of the User’s device; • the technical characteristics of the User’s device; • information about the browser used by the User and the language, the address assigned to the User’s computer (ID); • date and time of access to the Website, the time zone, territorial code, click data; • the addresses of the requested site pages, • details of the web site which the user came to the Site from; • other information concerning the User’s use of the Website.
4.4. The Company deletes personal data one (1) year after the date when the processing goals were achieved, unless otherwise provided for by the current legislation of the Russian Federation.
4.5. The Company has the right to use cookies. For more information about the cookies used by the Operator, see our Cookie Policy. By continuing to use the Website, you agree to the use of cookies. Cookies do not contain information that constitutes Personal Data but are aimed at Website personalizing for a specific user device. In addition, some third-party services may install cookies on your device and use them in their advertising campaigns, as the Operator uses such third-party services on its Website (for example, Google Analytics). Cookies are used to collect anonymous behavioral information that companies may use to provide personalized advertising. To disable this feature, go to http://optout.aboutads.info/ and follow the steps described there. The http://optout.aboutads.info/ service was created and is operated by third parties, and the Operator has no relation to the specified service and does not provide any express or implied guarantees in relation thereto; You can also disable these and other cookies in your browser settings. You may find detailed information about the cookies used and the opt-out conditions in the Cookie Policy.
4.6. The Company receives information about the IP address of the User’s device and the website with the link from which the visitor came. This information is not used to establish the identity of the Personal data subject.
5. Personal Data Processing Procedure
5.1. If the User withdraws its consent to the processing of personal data, the Company will cease the processing thereof or ensure the cessation of such processing (if personal data processing is implemented by another entity acting on behalf of the Company), and if the storage of personal data is no longer required for the purposes of personal data processing, the Company will destroy the personal information or ensure its destruction (if personal data processing is implemented by another entity acting on behalf of the Company) within seven (7) working days from the date when the User’s withdrawal statement was received.
5.2. The Company may delegate the processing of Personal Data to another entity. This being said, the Company will comply with the requirements for the order to process personal data provided for by Federal Law No. 152 “On Personal Data”.
5.3. The operator has the right to transfer personal data to the bodies of inquiry and preliminary investigation, judicial authorities and other authorized bodies on the grounds provided for by the current legislation of the Russian Federation.
6. Rights of the Personal Data Subject
6.1. The Personal Data Subject has the right (unless otherwise provided by law):
• to demand amendment of their personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights; • to request the list of their personal data processed by the Company and the source of such data; • to receive information about the terms of processing of their personal data, including the terms of the storage thereof; • to require notification of all persons who were previously provided with incorrect or incomplete personal data about any deletions, amendments or additions to such data; • to appeal to the authorized body for the protection of the rights of personal data subjects or in court against illegal actions or omissions in the processing of their personal data; • to protect their rights and legitimate interests, and seek compensation for damages and/or non-pecuniary damage award in court.
6.2. Personal data subjects can send their requests to the Operator at 119072, Moscow, Bersenevskaya emb., 6, bldg. 3, floor 4, suite I, room 9, LLC “Web3 Technology”, Legal Department.
7. Obligations of the Company
7.1. To use the personal data of the personal data subject exclusively for the purposes specified herein.
7.2. To ensure the confidentiality of personal data, not to disclose them without the prior written permission of the personal data subject, and not to sell, exchange, publish, or otherwise disclose the transferred personal data, except for the cases provided for in this Privacy Policy.
7.3. To take precautionary measures to protect the confidentiality of the personal data of the personal data subject in accordance with the procedure usually used to protect this type of information in business transactions.
7.4. To block the personal data of a User upon the request of a subject of personal data or their legal representative or an authorized body in charge of the protection of rights of personal data subjects for a period of the inspection in case of identification of inaccurate personal data or wrongful acts.
7.5. Take the necessary legal, organizational, and technical measures when processing personal data or ensure that they are taken in order to protect personal data from unauthorized or accidental access to it, its destruction, modification, blocking, copying, disclosure, or distribution, as well as from other illegal actions in relation to personal data.
8. Liability
8.1. If the Company fails to fulfill its obligations, it shall be liable for losses incurred by the personal data subject in connection with the illegal use of personal data, in accordance with the legislation of the Russian Federation.
8.2. In the event of loss or disclosure of confidential information, the Company shall not liable if the confidential information:
8.2.1. Became publicly known before its loss or disclosure;
8.2.2. Was received from a third party prior to its receipt by the Company; 8.2.3. Was disclosed subject to the consent of the personal data subject.
8.3. The Company’s management and employees are responsible for observing the requirements of Federal Law No. 152 “On Personal Data” by the Company. The responsibility for organizing the processing of personal data and ensuring the security thereof in accordance with the requirements of Federal Law No. 152 “On Personal Data” and this Privacy Policy is imposed on the structural divisions/officials responsible for ensuring the security and confidentiality of personal data.
9. Final Provisions
9.1. This Privacy Policy and the relations arising in connection herewith shall be governed by the law of the Russian Federation.
9.2. The Company may amend this Privacy Policy without the User’s consent. If the current version is amended, the date of the last update is specified herein. The new version of the Privacy Policy takes effect from the moment it is posted on the Website, unless otherwise provided in a new version of the Privacy Policy.
9.3. If you have any suggestions or questions concerning this Privacy Policy, send us an email at [email protected].
9.4. If you have any questions about the nature of the use, the actual use, modification, or deletion of your personal data that you have provided, or if you would like to opt-out of further processing by the Company, please contact us by email: [email protected].
9.5. Please note that the Company shall not be responsible for false information provided by the personal data subject.