Personal Data Processing and Protection Policy
1. General Provisions
This personal data processing and protection policy is drawn up in accordance with the requirements of the Federal Law of 07.27.2006. No. 152 "On Personal Data" of the Russian Federation and determines the procedure for processing personal data and measures to ensure the security of personal data taken by LLC "Positive Dialog Management Company" (hereinafter the "Operator").
1.1. The operator sets as his most important goal and condition for the implementation of his activities the observance of the rights and freedoms of man and citizen in case of collection and processing of its personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the httpsː//www.ixdcapital.com
website. 2. The main 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 suspension of personal data processing
(unless the processing is necessary to clarify personal data);
2.3. Website - a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address httpsː//www.ixdcapital.com
2.4. Personal data information system - a set of personal data contained in databases, and ensuring their processing of information technologies and technical means;
2.5. Anonymization of personal data - actions, as a result of which it is impossible to determine without the use of additional information the ownership of personal data to a specific User or other personal data subject;
2.6. Personal data processing - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
2.7. Operator - a state body, municipal body, legal or natural person, independently or jointly with other persons, organizing and (or) processing personal data, as well as determining 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 determined User of the httpsː//www.ixdcapital.com
2.9. User - any visitor to the httpsː//www.ixdcapital.com
2.10. Provision of personal data - actions aimed at the disclosure of personal data to a specific person or a certain circle of persons;
2.11. Dissemination of personal data - any actions aimed at disclosing personal data to an undefined circle of persons (transfer of personal data) or familiarizing oneself with personal data of an unlimited circle of persons, including disclosing personal data in the media, posting on information and telecommunication networks or providing access personal data in any other way;
2.12. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to a foreign government authority, a foreign individual or foreign legal entity;
2.13. Destruction of personal data - any actions as a result of which personal data is irrevocably destroyed with the inability to further restore the content of personal data in the personal data information system and (or) physical storages of personal data are destroyed. 3. The operator may process the following personal data of the User
3.1. Full Name;
3.2. Phone number;
3.3. E-mail address;
3.4. The site also collects and processes anonymous data about visitors (including cookies) using Internet statistics services (Yandex Metric and Google Analytics and others).
3.5. The above data are further incorporated in the text of the Policy by the general concept of Personal Data. 4. Purpose of processing personal data
4.1. The purpose of personal data processing is the conclusion, execution and termination of civil contracts; providing the User with access to services, information and / or materials contained on the httpsː//www.ixdcapital.com
website; clarification of order details.
4.2. The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The user can always refuse to receive informational messages by sending an email to the Operator at the email address email@example.com marked "Opt out of notifications of new products and services and special offers."
4.3. Anonymized user data collected using the Internet statistics services is used to collect information about the actions of users on the site, improve the quality of the site and its content. 5. Legal basis for the processing of personal data
5.1. The Operator processes the User's personal data only if it is filled and / or sent by the User independently through special forms located on the site https://www.ixdcapital.com
. By filling out the appropriate forms and / or sending your personal data to the Operator, the User expresses his consent to this Policy.
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
6.1. The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.
6.2. The User's personal data will never, under any circumstances, be transferred to third parties, with the exception of cases related to the implementation of applicable law.
6.3. In case of inaccuracies in personal data, the User can update it independently, by sending the Operator a notification to the Operator's email address firstname.lastname@example.org marked "Updating personal data."
6.4. The processing time for personal data is unlimited. The user can at any time withdraw his consent to the personal data processing by sending a notification to the Operator by e-mail to the operator's email address email@example.com with marked "Withdrawal of consent to the personal data processing" 7. Cross-border transfer of personal data
7.1. Before starting the cross-border transfer of personal data, the operator must make sure that the foreign state on whose territory it is supposed to transfer personal data provides reliable protection of the rights of the subjects of personal data.
7.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can only be carried out if there is a written consent of the personal data subject to the cross-border transfer of his personal data and / or the execution of the contract to which the personal data subject is a party. 8. Final provisions
8.1. The user can get any clarification regarding the processing of his personal data by contacting the Operator via e-mail firstname.lastname@example.org.
8.2. This document will reflect any changes in the policy of processing personal data by the Operator. The policy is valid indefinitely until it is replaced with a new version.
8.3. The current version of the Policy is freely available on the Internet at