Privacy Policy IntroductionWe understand that you ("Site User", "Subject of Personal Data") are aware of and care about your privacy interests, and we take that seriously. This Privacy Policy is designed to help you understand what data we collect, why we collect it, what we do with it, and sets out your privacy rights. Personal Data (PDN) - any information relating to a directly or indirectly identified or identifiable natural person (the data subject). We recognize that data privacy is our ongoing responsibility, and therefore we will update this Privacy Policy as we adopt new personal data processing practices or adopt new privacy policies. You, as a Site User, by starting (and/or continuing) to use this Site accept your obligations under the Website Usage Agreement. This Privacy Policy (hereinafter referred to as the "Policy") of Company - KEY Ltd. (Russian equivalent: ООО "ПРОЕКТНЫЙ КОНСУЛЬТАЦИОННЫЙ ЦЕНТР ""КЛЮЧ"" , ПКЦ "КЛЮЧ", ООО "КЛЮЧ", ИНН 6381009392, ОГРН 1056381013688)), hereinafter referred to as the "Company", establishes the scope, purposes and methods of processing personal data of individuals (Users of the site, subjects of personal data) who are not employees of the Company, and is published in the public domain in accordance with the requirements of the Federal Law of the Russian Federation "On Personal Data" № 152-FZ of 27.07.2006г. The Company's activities in accordance with this Privacy Policy ensure the protection of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrecy.1. Legal basis of personal data processingThe legal grounds for processing personal data are: Article 6 of the Federal Law of the Russian Federation "On Personal Data", federal laws of the Russian Federation and regulatory legal acts adopted on their basis, regulating relations related to the activities of the subject of Personal Data and the Company; the Company's statutory documents; contracts concluded between the subject of Personal Data and the Company; consent of the subject of Personal Data to the processing of personal data.2. User's consent to the processing of personal dataBy sending a message through the feedback forms on the website, the website User expresses his/her consent to the processing of personal data for the purposes and to the extent specified in this Policy.By registering on the Company's website, the subject of personal data expresses his/her consent to the processing of his/her personal data to the extent necessary to create an account.The user of the Company's site may subscribe to receive e-mail newsletters, if such an opportunity is provided by the site. The mailing may contain information about news, analytical materials, events held by the Site and the like. By filling in the "e-mail" field the user gives his/her consent to receive such mailings. The User can revoke his/her consent to receive mailings at any time. The opportunity to unsubscribe from the mailing list is provided to the user in each e-mail.3. Purpose and procedure of personal data processingThe purpose of personal data processing is to improve the User's experience on our website and to provide the User with the services requested by the User, as well as to provide the User with information about the Company, including the terms of contracts, services provided, ongoing promotions and special offers; to analyze the quality of service provided by the Company and improve the quality of customer service of the Company; to execute the contract; to provide services; to record the services provided to consumers for mutual settlements, If a website user is simply browsing the Company's website, no personal data is processed.The anonymized data of Users collected through Internet statistics services are used to collect information about Users' actions on the website, to improve the quality of the website and its content.The Company may process Personal Data:- by the Company's employees;
- other persons processing Personal Data on behalf of the Company.
Processing of Personal Data by other persons may be carried out on the basis of a relevant agreement with the Company, which contains an instruction to process Personal Data. The instruction shall specify the list of actions (operations) with Personal Data to be performed by the person processing the Personal Data and the purposes of processing, shall establish the obligation of such person to maintain the confidentiality of Personal Data and ensure the security of Personal Data during their processing, and shall specify the requirements for the protection of the Personal Data being processed in accordance with Article 19 of the Federal Law "On Personal Data". The Company may process Personal Data with or without the use of automation tools. Automated processing of Personal Data shall be carried out by the Company in strict compliance with this Policy. The Company is prohibited from making decisions based solely on the automated processing of Personal Data that give rise to legal consequences with respect to the subject of Personal Data or otherwise affect his or her rights and legitimate interests, except as provided for by the laws of the Russian Federation.4. Volume of processed personal dataThe Company processes the following personal data of individuals who are not employees of the Company: Surname, first name, patronymic; e-mail address; telephone numbers; messenger account data; year, month, date and place of birth; address; photos; information about education, profession, specialty and qualifications; information about the organization, position; information about location; ip address; type and version of OS; type and version of Browser; type of device and its screen resolution; language of OS and Browser.The site also collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrics and Google Analytics and others), as well as other data and information that the User of the site sends to the Company by filling out the appropriate forms on the site. The above-mentioned data is further on in the text of the Policy united by the general concept of Personal Data (PDn).Legal basis for processing personal data:-The Company processes the User's personal data only if it is filled in and/or sent by the User himself/herself through special forms located on the website www.ai-key-ai.ru (ai-key-ai.ru). By filling in the relevant forms and/or sending their personal data to the Company, the User expresses their consent to this Policy.-The Company processes anonymized data about the User, if it is allowed in the User's browser settings (cookies are enabled).The website uses cookie technology, which are small text files in which the browser records data from websites visited by the user. This data is used to collect information about visitors' activities on the site, to improve the quality of its content and features.At any time, the User may change the settings in their browser so that the browser stops saving all cookies and notifies them when they are sent. In this case, some services and functions of the site may stop working or may not work properly.5. Cookies files"Cookie" is a small text file that is sent by a web server and stored on your computer, cell phone or any other Internet-enabled device when you visit a website or mobile application. Each time you open a page on the relevant website, your web client (web browser) sends this text file to a web server as part of an HTTP request to provide that web server with information about your online activities or preferences. However, to ensure the security and safety of your data, your web client (web browser) generally does not transmit cookies intended for one website to other resources. For the purposes of this Policy, cookies shall hereinafter also mean any other similar technologies.This site uses cookies to provide enhanced site functionality (for example, to help you stay logged in to your account when you close and reopen your browser or to save your bookmarks) and to collect traffic data (for example, which pages are the most popular). These cookies may be provided by either first-party or third-party vendors. Our site also collects limited information (user agent, HTTP referrer, last URL requested by the user, client-side and server-side clickstream) about visits to our site; we may use this information to analyze overall traffic patterns and perform ongoing system maintenance. You have many options for managing cookies on your computer. All major browsers allow you to block or delete cookies from your system. To learn more about your options for managing cookies and web beacons, please review your browser's privacy features.What kind of "cookies" do we use?Mandatory Cookies - Mandatory cookies are necessary for the basic operation of the Company's website and to provide services explicitly requested by you. Such services may include selecting your country and language, saving your login status, providing security and fraud prevention, saving shopping cart and wish list items while you browse the site, saving volume settings, and accessing secure areas of our website. This category of cookies cannot be disabled and does not require your consent;Analytical (performance) cookies are non-mandatory cookies that are necessary to collect information about how you use the Company's website (for example, what web client (web browser) you use to visit the site), which allows us to improve the navigation of the site, make it more user-friendly and responsive to your needs, as well as correct technical errors as they occur, and keep the site secure. For example, this type of cookie helps us understand how a user accesses, browses or uses the site and identify ways to optimize the site. We seek your consent to place these types of cookies on the Company's website.Company advertising (/marketing) cookies - These cookies are optional and are used to collect information about your search preferences and are used to deliver you the most relevant advertising and content to your interests. They are also used to limit the number of times an advertisement is displayed and to measure the effectiveness of advertising campaigns (conversion rates). We ask for your consent to place these types of cookies on our Site.Third Party Advertising (/marketing) Cookies - These cookies are optional and allow third parties to collect cookies to enable us to use targeted marketing/advertising of our products and services on other websites, apps and social media. Your consent includes authorizing these third parties to set cookies that track your interests and activities, including the products and services you are interested in or purchase, on our Site and other websites, social media sites, applications and devices. Please be advised that these third parties are joint or independent operators of personal data collected through cookies, which they may use for their own purposes. We allow these third parties to place cookies on our Site. To find out how these third parties process your personal information, please click here: Google; Yandex We seek your consent to the placement of these types of cookies by the above third parties.This Company website may also use Google Analytics, Google Tag Manager, GA Audiences and DoubleClick, web analytics services and tools provided by Google, Inc. ("Google"). Google uses "cookies", which are text files placed on your computer, to help the website analyze how users use the website. The information associated with the cookie about your use of the website (including your IP address) may be transmitted to Google and stored on its servers, which are located in many countries around the world. Google will use this information to evaluate your use of the website, to compile reports on website activity for website operators and to provide other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law or where such third parties process the information on Google's behalf. Google will not link your IP address to any other data stored by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do so, you may not be able to use the full functionality of this website. You can also opt out of Google's personalized advertising by visiting Ads Settings. To learn more about Google's data collection and processing practices, please see Google's Privacy Policy.How do I refuse cookies?Cookies are placed on your device. In other words, we (the Company) cannot delete them for you. You should do this yourself, following the instructions applicable to your device. If you are on a website operated by the Company, you can also avoid cookies being placed on your device by adjusting your browser settings accordingly. Browser cookies have a limited shelf life. However, similar technology solutions, such as local storage on your device, do not have a built-in self-deletion system after a period of time and must be deleted by you. Below we have provided instructions on how to set/delete cookies for the most popular devices. Examples of guides to blocking and deleting cookies in various browsers for PCs and Macs: Internet Explorer; Google Chrome; Mozilla Firefox; Opera6. Confidentiality of personal dataThe site does not disclose to third parties and does not distribute personal data of the site users without their consent except in cases provided by federal law.The security of personal data processed by the Company is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of applicable legislation in the field of personal data protection.7. Period of personal data processingPersonal Data provided by the user shall be processed until the Company is liquidated (reorganized). Personal Data whose processing (storage) period has expired shall be destroyed, unless otherwise provided for by federal law or the Company's regulatory documents. The period of processing of Personal Data may be limited by withdrawal of the Data Subject's consent to the processing of his/her personal data.8. Rights of the personal data subjectA personal data subject has the right to submit a written request to the Company for information regarding the processing of his/her personal data in accordance with the requirements of Article 14 of the Federal Law of the Russian Federation "On Personal Data".This request can be sent to the following e-mail address: info@ai-key-ai.ru9. Protection of personal dataThe Company shall take measures necessary and sufficient to ensure fulfillment of the obligations stipulated by the Federal Law "On Personal Data" and regulatory legal acts adopted in accordance therewith.The Company shall independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of such obligations, in particular:1) a person responsible for organization of personal data processing is appointed;2) local acts on personal data processing and protection were developed and approved;3) legal, organizational and technical measures to ensure personal data security shall be applied:- threats to the security of personal data during their processing in personal data information systems are identified;- the rules of access to the data processed in the personal data information system are established, as well as the registration and recording of all actions performed with personal data in the personal data information system is ensured4) control over the measures taken to ensure personal data security and the level of protection of personal data information systems shall be exercised;5) assessment of the damage that may be caused to the personal data subject in case of violation of the requirements of the current legislation of the Russian Federation, the correlation between the said damage and the measures taken by the Company aimed at ensuring the fulfillment of obligations under the current legislation of the Russian Federation;6) the conditions preventing unauthorized access to the material carriers of personal data and ensuring the safety of personal data are observed;7) the Company's employees who directly process personal data are familiarized with the provisions of the Russian Federation legislation on personal data, including the requirements to personal data protection, local acts on personal data processing and protection.Cross-border transfer of personal data:-Before commencing a transborder transfer of personal data, the Company shall make sure that the foreign state to whose territory the transfer of personal data is to be carried out ensures reliable protection of the rights of personal data subjects.-Transborder transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only if the personal data subject consents in writing to the transborder transfer of his/her personal data and/or if the contract to which the personal data subject is a party is executed.In order to ensure confidentiality of information and protection of personal data, the Company maintains an appropriate IT environment and takes all measures necessary to prevent unauthorized access.10. Final provisions- The User's personal data will never, under no circumstances, be disclosed to third parties without proper authorization of the subject of Personal Data, except in cases related to the execution of applicable law.
- In case of identification of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator to the Company's e-mail address info@ai-key-ai.ru with the note "Personal Data Update". Responsibility for timely submission to the Company of information on changes in personal data processed by the Company rests with the subjects of personal data to whom they belong.
- The website user may obtain any clarifications on any questions concerning the processing of his/her personal data by contacting the Company via e-mail at info@ai-key-ai.com.
- This document will reflect any changes to the Company's personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.
- The current version of the Policy is freely available on the Internet at: https://ai-key-ai.com/key-ltd_privacy_policy .