1. Basic concepts

1.1. Personal data is any information related directly or indirectly to a specific or identifiable User (Subject of personal data) that can be transmitted by a User using the Site.

1.2. The platform is a website located on the Internet at: https://site.factoring.cybertown.pro

1.3. The User (Subject of personal data) is an individual who is a user of the Platform.

1.4. The Operator is a Limited Liability Company "FACTORING PLATFORM", which processes the User's personal data.

1.5. Personal data processing is any action (operation) or a set of actions (operations) of the Operator performed using automation tools and (or) without using such tools with the User's personal data, including collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of the User's personal data.

1.6. Automated processing of personal data is the processing of personal data using computer technology.

1.7. Dissemination of personal data — actions aimed at disclosing the User's personal data to an indefinite circle of persons.

1.8. Provision of personal data — actions aimed at disclosing the User's personal data to a certain person or a certain circle of persons.

1.9. Blocking of personal data is the temporary termination of the processing of the User's personal data (except in cases where processing is necessary to clarify personal data).

1.10. Destruction of personal data — actions as a result of which it becomes impossible to restore the content of the User's personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed.

1.11. Cookies are data from cookies, as defined in the Cookie Policy.

2. General provisions

2.1. This Privacy Policy defines the procedure for processing and protecting User information, including User data, which the Platform may receive during registration/authorization and/or use of the software product.

2.2. Using the Platform means that the User agrees to this Policy and the conditions for processing personal data specified therein. In case of disagreement with these terms, the User must refrain from using the Platform.

2.3. When processing personal data, the Operator is guided by Federal Law No. 152-FZ of 27.07.2006 "On Personal Data", Federal Law No. 149-FZ of 27.07.2006 "On Information, Information Technologies and Information Protection" and other applicable Russian legislation.

3. Personal data of Users that the Operator receives and processes

3.1. The composition of the information that the Operator collects and processes:

3.2. During the User's visit to the Platform, the Operator has access to technical information that is automatically collected by the Platform during the visit. During the User's visit to the Platform, information from standard server logs and cookie data is automatically available. Such as the IP address of the personal computer (proxy server), the name of the Internet provider, the domain name, the type of browser, the operating system, the pages of the Platform visited by the User, the date and time of the visit. The user can change the settings of his browser at any time so that cookies are blocked or notifications about their sending are received. At the same time, the User should understand that some functions and Platforms may not work correctly.

3.3. The Operator does not:

• directly or indirectly identify Users using technical information or other information;
• matching or combining (linking) technical information with the User's personal data held by the Operator;
• processing of technical information for analytical and marketing (advertising) purposes;
• transfer of technical information to third-party Internet services.

3.4. The personal data provided by the User may be verified by the Operator for authenticity by re-confirming the User's personal data only if they meet the purposes of their processing, or in cases provided for by the relevant regulatory legal act of the Russian Federation, or an agreement (to which the User is a party, beneficiary or guarantor).

3.5. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, or intimate life.

3.6. The Operator does not process biometric personal data.

4. The procedure and grounds for Processing personal data of Users

4.1. The processing of the User's personal data is carried out by the Operator with the User's consent to the processing of personal data. The User's consent to the processing of personal data is considered received by the Operator from the moment the User places a special mark in the appropriate field of the registration form posted on the Platform.

4.2. The operator performs automated processing of personal data.

4.3. The operator processes personal data in a form that allows to identify the Subject of personal data, no longer than the purposes of personal data processing require.

4.4. Upon achieving the purposes of processing personal data, as well as in the case of withdrawal of the User's consent to processing, personal data is subject to destruction, except in cases provided for by law.

4.5. The Operator implements the following requirements for the protection of personal data:

• requirements for the confidentiality of personal data;
• requirements for ensuring the accuracy of personal data, and, if necessary, relevance to the purposes of personal data processing (with the adoption (ensuring acceptance) of measures to delete or clarify incomplete or inaccurate data);
• requirements for the protection of personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
• requirements to ensure that the Subject of personal data exercises his rights, including the right to access information;
• other requirements stipulated by the legislation.

4.6. The Operator may use the User's personal data and information for the purpose of:

• handle User requests and support requests, as well as provide information and access to the Platform;
• manage the Platform, system administration and security;
• compile summary statistics on the operation and use of the functionality or capabilities of the Platform in order to better understand User preferences;
• send Users technical alerts, reports, updates, security notifications and other messages related to the maintenance of the Platform;
• conduct research and development to improve the Platform;
• investigate and prevent fraud, unauthorized access or use of the Platform, violations of terms and policies, and other illegal behavior.

4.7. The processing ensures the accuracy of personal data, their sufficiency and relevance in relation to the purposes of personal data processing. If inaccurate or incomplete Personal Data is found, they are clarified and updated.

4.8. The Operator stops processing personal data in the following cases:

• achieving the purpose of personal data processing;
• amendment, invalidation of regulatory legal acts establishing the legal basis for the processing of personal data;
• identification of illegal processing of personal data carried out by the Operator;
• withdrawal of the User's consent to the processing of his personal data, if, in accordance with the provisions of Federal Law No. 152-FZ dated 07/27/2006 "On Personal Data", the processing of these personal data is allowed only with the consent of the Personal Data Subject.

4.9. The destruction of personal data by the Operator is carried out in accordance with the procedure and time limits provided for by Federal Law No. 152-FZ of 27.07.2006 "On Personal Data".

4.10. The Operator does not provide or disclose information containing the User's personal data to a third party without the User's written consent, except in cases where this is necessary in order to prevent threats to life and health, as well as in cases established by the legislation of the Russian Federation.

5. Purposes of processing Users' personal information

5.1. The Operator processes Users' personal data for the following purposes:

• identification of the User registered on the Operator's Platform for further authorization and other actions.
• providing the User with access to personalized data of the Operator's Platform (including Personal Account).
• establishing feedback with the User, including sending notifications, requests regarding the use of the Operator's Platform, providing services and processing requests and requests from the User.
• determining the User's location to ensure security and prevent fraud.
• confirmation of the accuracy and completeness of the personal data provided by the User.
• creating an account to use parts of the Operator's Platform, if the User has agreed to create an account. User notifications via email.
• providing the User with effective technical support in case of problems related to the use of the Platform.
• conclusion of any contracts with the User and their further execution.

6. Measures taken to protect Users’ personal data

6.1. The operator takes necessary and sufficient organizational and technical measures to protect personal User data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions with personal data of third parties.

6.2. For additional protection of the User account, two-factor authentication is provided.

7. Rights and obligations of the Operator and User

7.1. As part of the processing of personal data, the following rights and responsibilities.

7.2. The user has the right:

• receive information regarding the processing of his personal data in the manner, form and time frame established Legislation on personal data;
• demand clarification of your personal data, their blocking or destruction if personal the data is incomplete, outdated, unreliable, illegally obtained, is not necessary for stated purpose of processing or are used for purposes not previously stated when the User provided consent to the processing of personal data;
• take measures provided by law to protect your rights;
• withdraw your consent to the processing of personal data by sending a written notification to the email address: factoring@cybertown.pro with the mark “revocation of consent to the processing of personal data”, while the User’s withdrawal of consent to the processing of personal data entails the deletion of the user account on the Platform.

7.3. The user is obliged:

• provide the Operator with reliable information about yourself;
• inform the Operator about clarification (updating, changing) of your personal data.

7.4. The operator has the right:

• process the User’s personal data in accordance with the stated purpose;
• require the User to provide reliable Personal data necessary for the execution of agreement, provision of services, identification of the User, as well as in other cases provided for Legislation on personal data;
• process publicly available Personal Data of individuals;
• entrust the Processing of personal data to another person with the consent of the Personal Data Subject.

7.5. The operator is obliged:

• provide the User, at his request, with information regarding the processing of his personal data;
• organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
• respond to requests and requests from Users and their legal representatives in accordance with the requirements Personal Data Law;
• report to the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 10 days from the date of receipt of such a request;
• publish or otherwise provide unrestricted access to this Privacy Policy;
• take legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, distribution personal data, as well as from other unlawful actions in relation to personal data;
• stop transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
• perform other duties provided for by the Personal Data Law.

8. Confidentiality

8.1. The User's personal data is confidential information that is not subject to disclosure and cannot be used by the Operator for purposes not listed in this Policy. Disclosure of personal data in this Policy means an action or omission as a result of which personal data, in any possible form (oral, written, or other form, including using technical means), becomes known to third parties without the consent of the owner of such information or contrary to a civil contract.

8.2. Disclosure of the User's personal data or part of it is allowed only in cases provided for by the current legislation of the Russian Federation, including in accordance with the requirements of Federal Law No. 63-FZ dated 04/06/2011 "On Electronic Signature", or with the User's separate consent.

8.3. The Operator does not transfer the User's personal data across borders.

9. Final provisions

9.1. This Policy is an internal document of the Operator, is publicly available and is subject to posting on the Platform.

9.2. This Policy comes into force from the moment it is published on the Platform and applies to the User's personal data received both before and after the entry into force of this Policy.

9.3. The Operator has the right to amend this Policy unilaterally or approve a new version of the Policy by publishing a new version of the Policy or changes to it on the Platform. The User must independently monitor changes in the Policy.

9.4. This Policy, the relations between the User and the Operator arising in connection with the application of this Policy, as well as issues not regulated by this Policy, are governed by the current legislation of the Russian Federation.

10. Feedback. Questions and suggestions

10.1. Users have the right to request information from the Operator regarding the processing of their personal data. To do this, send a request to the following email address: factoring@cybertown.pro. The User's request must contain the information provided for in part 3 of Article 14 of the Law on Personal Data.

10.2. Users have the right to send requests for clarification, updating of personal data, and applications for revocation of consent to the processing of personal data to the email address specified in clause 10.1 of the Policy.

11. Operator's details