Privacy Policy
This is an English translation of the Personal Data Processing Policy of Mobilnye Tekhnologii LLC, provided for convenience. If there is any discrepancy between this translation and the Russian original, the Russian version prevails.
1. General provisions
1.1. This Personal Data Processing Policy (the “Policy”) has been prepared in accordance with Federal Law of the Russian Federation No. 152-FZ “On Personal Data” of 27 July 2006 (the “Law”). It sets out how and on what terms the Operator processes personal data and the measures it takes to keep that data secure.
1.2. The personal data operator (the “Operator”) is:
- Name
- Limited Liability Company “Mobilnye Tekhnologii” (in Russian: ООО «Мобильные технологии»)
- Taxpayer ID (INN) / Registration No. (OGRN)
- [INN] / [OGRN]
- Registered address
- [registered address]
- Postal address
- [postal address]
- Entry in the Roskomnadzor register of personal data operators
- [register entry number]
1.3. This Policy applies to all personal data the Operator receives from visitors to the website mobtechgroup.com (the “Website”) and from anyone who contacts the Operator using the details published on the Website.
1.4. This Policy is published on the Website and is freely accessible, as required by Article 18.1(2) of the Law. By using the Website or contacting the Operator, you confirm that you have read this Policy.
1.5. The Website is not intended for anyone under the age of 18. The Operator does not knowingly collect personal data from minors.
2. Definitions
- Personal data — any information relating directly or indirectly to an identified or identifiable individual (the “data subject”).
- Processing of personal data — any operation or set of operations performed on personal data, whether or not by automated means, including collection, recording, organisation, accumulation, storage, adaptation or alteration, retrieval, use, transfer (provision, access), depersonalisation, blocking, erasure and destruction.
- Automated processing — processing of personal data using computer equipment.
- Provision of personal data — actions aimed at disclosing personal data to a specific person or group of persons.
- Blocking — temporary suspension of processing (except where processing is needed to correct the data).
- Destruction — actions that make it impossible to restore the content of personal data in an information system and/or that destroy the physical media containing it.
- Cookies — small pieces of data that the Website stores in your browser and that your browser sends back when you visit the Website again.
3. Rights and obligations of the Operator
3.1. The Operator may:
- determine the measures necessary and sufficient to meet its obligations under the Law;
- engage another party to process personal data on its behalf, with the data subject’s consent unless the law provides otherwise, under a contract with that party;
- continue processing personal data without the data subject’s consent where the Law provides grounds for doing so, including after consent has been withdrawn.
3.2. The Operator must:
- process personal data in accordance with the Law;
- respond to requests and enquiries from data subjects and their representatives;
- provide Roskomnadzor, at its request, with the necessary information within 10 business days of receiving the request;
- take legal, organisational and technical measures to protect personal data from unauthorised or accidental access, destruction, alteration, blocking, copying, provision, distribution and any other unlawful actions;
- in the event of an unlawful or accidental transfer (provision, distribution) of personal data, notify Roskomnadzor within the time limits set by Article 21(3.1) of the Law: within 24 hours of the incident itself and within 72 hours of the results of the internal investigation.
4. Your rights
4.1. As a data subject, you have the right to:
- receive information about how your personal data is processed, in the manner, form and time frames set by the Law;
- ask for your personal data to be corrected, blocked or destroyed if it is incomplete, out of date, inaccurate, unlawfully obtained or not necessary for the stated purpose;
- withdraw your consent to the processing of your personal data;
- ask the Operator to stop processing your personal data;
- appeal against the Operator’s actions or inaction to Roskomnadzor or in court;
- exercise any other rights provided by the laws of the Russian Federation.
4.2. Please send requests to company@mobtechgroup.com or to the Operator’s postal address. Your request must include enough information to identify you and to confirm that you have interacted with the Operator (Article 14(3) of the Law).
5. Principles of processing
- personal data is processed lawfully and fairly;
- processing is limited to specific, predefined and legitimate purposes;
- databases containing personal data processed for incompatible purposes are not combined;
- only personal data relevant to the purposes of processing is processed, and its content and volume match those purposes;
- personal data is kept accurate, sufficient and up to date;
- personal data is stored in a form that allows the data subject to be identified for no longer than the purposes of processing require, unless a longer period is set by law or contract;
- once the purposes of processing have been achieved, or are no longer needed, personal data is destroyed or depersonalised.
6. Purposes, data, legal grounds and retention
6.1. Handling enquiries and preparing commercial proposals (media plans)
- Data subjects
- people who contact the Operator by email or messenger, including representatives of prospective clients
- Personal data
- full name; email address; messenger username and profile name; phone number (if provided); company name and job title; any other information you choose to include in your message
- Category
- general personal data (no special-category or biometric data is processed)
- Legal grounds
- Article 6(1)(5) of the Law — processing is necessary to enter into a contract at the request of the data subject or the party they represent; Article 6(1)(7) of the Law — the Operator’s legitimate interests
- Method
- mixed (automated and non-automated)
- Retention period
- until the purpose of processing is achieved; if no contract is concluded, no longer than 3 years from the date of the last contact
- Destruction
- deletion from the Operator’s information systems within 30 days of the purpose being achieved or of receiving the data subject’s request, documented in a destruction record
6.2. Web analytics: visit statistics and Website improvement
- Data subjects
- Website visitors
- Personal data
- cookie identifiers; IP address; browser, device and operating system information; screen resolution; language; date and time of visit; pages viewed and referral source; actions on the Website
- Category
- general personal data
- Legal ground
- Article 6(1)(1) of the Law — consent of the data subject, given by clicking “Accept” in the cookie notice
- Method
- automated, using the Yandex Metrica service (YANDEX LLC), which processes the data on the Operator’s behalf
- Retention period
- until consent is withdrawn, but no longer than 1 year from the last visit to the Website
- Destruction
- cookies are removed from the browser and data collection stops once consent is withdrawn; data in the analytics service is deleted within 30 days
6.3. Keeping the Website running and secure
- Data subjects
- Website visitors
- Personal data
- IP address; browser information; date and time of the request; URL of the requested page; the visitor’s choice in the cookie notice
- Category
- general personal data
- Legal ground
- Article 6(1)(7) of the Law — the Operator’s legitimate interests (operating and protecting the Website)
- Method
- automated
- Retention period
- no longer than 6 months
- Destruction
- logs are deleted automatically when the retention period expires
7. How personal data is processed
7.1. The Operator collects, records, organises, accumulates, stores, corrects, retrieves, uses, blocks, erases and destroys personal data.
7.2. When collecting personal data of citizens of the Russian Federation, the Operator records, organises, accumulates, stores, corrects and retrieves it using databases located in the Russian Federation (Article 18(5) of the Law).
7.3. The Operator does not transfer personal data across borders.
7.4. The Operator does not disclose personal data to third parties or make it public without the data subject’s consent, unless federal law provides otherwise. Personal data may be provided to public authorities in the cases and in the manner established by law.
7.5. Anyone the Operator engages to process personal data on its behalf must follow the principles and rules of processing set out in the Law and keep the data confidential and secure.
7.6. To protect personal data, the Operator in particular: appoints a person responsible for organising personal data processing; adopts internal policies on processing; restricts employee access to personal data and trains staff on legal requirements; uses information security and anti-virus tools; backs up data and ensures it can be restored; and carries out internal checks that processing complies with the Law.
7.7. The Operator does not process special categories of personal data or biometric data, and does not make decisions with legal effects for the data subject based solely on automated processing.
8. Cookies
8.1. The Website uses two types of cookies:
- essential cookies — keep the Website working and remember your choices (language, theme and your decision in the cookie notice). They do not require consent and are not used for analytics;
- analytics cookies — set by Yandex Metrica to help us understand how visitors use the Website. They are only set after you click “Accept” in the cookie notice.
8.2. You can change your choice at any time using the “Cookie settings” link at the bottom of the Website, and you can delete cookies or block them in your browser settings. Declining analytics cookies does not limit your access to the Website.
9. Updating, correcting and deleting personal data; responding to requests
9.1. The information listed in Article 14(7) of the Law is provided to the data subject or their representative within 10 business days of the request. This period may be extended by no more than 5 business days, with a reasoned notice.
9.2. If inaccurate personal data is identified, the Operator corrects it within 7 business days. If unlawful processing is identified, the Operator stops it within 3 business days and, if processing cannot be made lawful, destroys the data within 10 business days.
9.3. When consent is withdrawn or the purpose of processing is achieved, the Operator stops processing and destroys the personal data within 30 days, unless a contract or the law provides otherwise and the Operator has no other lawful grounds for processing.
9.4. A request to stop processing personal data is fulfilled within 10 business days of receipt (Article 21(5.1) of the Law).
10. Final provisions
10.1. The Operator may amend this Policy. The new version takes effect when it is published on the Website, unless the new version states otherwise.
10.2. Person responsible for organising personal data processing: [full name, position], company@mobtechgroup.com.
10.3. Any matters not covered by this Policy are governed by the laws of the Russian Federation.