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Personal data processing policy

1. General provisions

This personal data processing policy has been drawn up in accordance with Federal Law No. 152-ФЗ of 27.07.2006 “On Personal Data” and sets out the procedure for processing personal data and the measures taken by CUBE SOFT SOLUTION S.R.L. (hereinafter the Operator) to protect personal data.

The Operator considers respect for human and civil rights and freedoms when processing personal data, including the protection of privacy and personal and family confidentiality, to be a primary objective and a condition of its activities.

This personal data processing policy of the Operator (hereinafter the Policy) applies to all information that the Operator may obtain about visitors to the website https://ru.cool-air.org/.

2. Main terms used in the Policy

Automated processing of personal data means processing personal data using computer equipment;

Blocking of personal data means temporarily suspending the processing of personal data, except where processing is necessary to clarify the personal data;

Website means a collection of graphic and information materials, computer programs and databases that make them accessible on the internet at https://ru.cool-air.org/;

Personal data information system means the collection of personal data held in databases and the information technologies and technical equipment used to process it;

Anonymisation of personal data means actions that make it impossible, without additional information, to determine whether personal data belongs to a particular User or another personal data subject;

Processing of personal data means any action or set of actions performed on personal data, with or without automation, including collection, recording, organisation, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (dissemination, provision or access), anonymisation, blocking, deletion and destruction;

Operator means a state authority, municipal authority, legal entity or individual that, independently or jointly with others, organises or performs the processing of personal data and determines the purposes of processing, the personal data to be processed and the actions or operations to be performed on it;

Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://ru.cool-air.org/;

User means any visitor to the website https://ru.cool-air.org/;

Provision of personal data means actions aimed at disclosing personal data to a particular person or a particular group of persons;

Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or making it available to an unlimited group of persons, including publishing personal data in the media, placing it on information and telecommunications networks or providing access to it in any other way;

Cross-border transfer of personal data means transferring personal data to the territory of a foreign state, to an authority of that foreign state, a foreign individual or a foreign legal entity;

Destruction of personal data means any actions that irreversibly destroy personal data, making it impossible to restore its content in the personal data information system, and/or actions that destroy the physical media containing the personal data.

3. Personal data of the User that the Operator may process

Surname, given name and patronymic;

Email address;

Telephone numbers;

The website also collects and processes anonymised visitor data, including cookies, through internet statistics services such as Yandex Metrica, Google Analytics and others.

The data listed above is referred to collectively as Personal Data in this Policy.

4. Purposes of processing personal data

The purpose of processing the User’s personal data is to inform the User by email and provide the User with access to services, information and/or materials available on the website.

The Operator may also notify the User about new products and services, special offers and various events. The User may opt out of these informational messages at any time by emailing the Operator at sale@cool-air.org with the subject “Opt out of notifications about new products and services and special offers”.

Anonymised User data collected through internet statistics services is used to gather information about Users’ actions on the website and improve the quality of the website and its content.

5. Legal grounds for processing personal data

The Operator processes the User’s personal data only when the User independently fills in and/or submits it through the special forms on the website https://ru.cool-air.org/. By completing the relevant forms and/or sending personal data to the Operator, the User agrees to this Policy.

The Operator processes anonymised User data where the User’s browser settings allow it, with cookies and JavaScript enabled.

6. Collection, storage, transfer and other processing of personal data

The security of personal data processed by the Operator is ensured through the implementation of the legal, organisational and technical measures necessary to comply fully with the requirements of applicable personal data protection legislation.

The Operator safeguards personal data and takes all possible measures to prevent unauthorised persons from accessing it.

The User’s personal data will never, under any circumstances, be transferred to third parties, except where this is necessary to comply with applicable law.

If the User identifies inaccuracies in their personal data, they may update it by notifying the Operator at sale@cool-air.org with the subject “Update of personal data”.

The period for processing personal data is unlimited. The User may withdraw consent to the processing of personal data at any time by notifying the Operator by email at sale@cool-air.org with the subject “Withdrawal of consent to personal data processing”.

7. Cross-border transfer of personal data

Before undertaking a cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the personal data is to be transferred provides reliable protection for the rights of personal data subjects.

Cross-border transfers of personal data to foreign states that do not meet the requirements above may be made only with the personal data subject’s written consent to the cross-border transfer of their personal data and/or for the performance of a contract to which the personal data subject is a party.

8. Final provisions

The User may obtain clarification about any questions concerning the processing of their personal data by contacting the Operator by email at sale@cool-air.org.

Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until it is replaced by a new version.

The current version of the Policy is freely available on the internet at https://ru.cool-air.org/policy/.