Personal data processing policy

1. General provisions

The current personal data processing policy is designed in compliance with the statutory requirements and determines the procedure and principles for processing personal data as well as personal data security measures taken by CRM Sensor LLC (hereinafter referred to as Operator).

1.1. Operator’s critical goal and prerequisite is to observe the rights and liberties of an individual and a citizen when processing personal data, including protection of rights to personal and family privacy.

1.2. The current personal data processing policy (hereinafter referred to as Policy) shall apply to all information and data that the Operator can obtain about CRMSensor user.


2. Basic terms and definitions of the Policy

2.1. Automated personal data processing – personal data processing via PC software;

2.2. Personal data blocking – temporary interruption of personal data processing (except where processing is required for rectification of personal data);

2.3. Website is a set of graphic materials and data, as well as software applications and databases ensuring their availability on the Internet;

2.4. Personal data information system is a set of personal data included into databases, as well as software applications and tools used for their processing;

2.5. Personal data depersonalization means actions making it impossible to identify personal data as related to a certain user or another data subject without involving additional information;

2.6. Personal data processing means any action (operation) or a series of actions (operations) performed towards personal data with or without the software, including the personal data acquisition, recording, systematization, accumulation, storage,  rectification (update or alteration), extraction, use, transfer (distribution, presentation, providing access), depersonalization, blocking, deleting and annihilation;

2.7. Operator – state authority, municipal authority, legal or private person, who severally or jointly arranges and (or) performs personal data processing, as well as defines the aims of personal data processing, the scope of personal data to processing, actions (operations)  performed towards personal data;

2.8. Personal data – any information related to directly or indirectly specified User;

2.9. User – any software/App user;

2.10. Personal data presentation – personal data disclosure to particular person or certain group of persons;

2.11. App means CRMSensor software;

2.12. Personal data distribution – any actions directed to personal data disclosure to indefinite range of persons (disclosure of personal data) or for personal data review by indefinite range of persons, including personal data publishing in mass media, placement in information and telecommunication networks or providing access to personal data in any other way;

2.13. Cross-border transfer of personal data – personal data transfer to a foreign country, foreign government body and foreign natural or legal person;

2.14. Personal data annihilation  – any actions resulting in irrevocably destruction of personal data making it impossible to restore personal data scope in the personal data information system and (or) resulting in the elimination of tangible personal data carriers


3. Operator can process the following personal data of User

3.1. Surname, first name, patronymic;

3.2. Telephone number;

3.3. E-mail;

3.4. Other personal data provided by User;

3.5. The above mentioned shall be hereinafter together referred to as Personal data.


4. Purpose of personal data processing

4.1. The purpose of User personal data processing is to provide User’s access to the App.


5. Legal basis for personal data processing

5.1. Operator processes User personal data only if the User filled in and/or sent the data  without any assistance through special forms in the App. By filling out appropriate forms and/or sending personal data to the Operator the User gives his/her consent to this Policy.


6. Procedure for personal data acquisition, storage, transfer and any other processing forms

Security of personal data processed by the Operator shall be provided by implementation of legal measures as well as arrangements and technical controls   necessary to fully comply with the applicable statutory requirements in the area of personal data protection.

6.1. Operator ensures personal data security and takes all possible actions to exclude unauthorized persons’ access to personal data.

6.2. Personal data is not permitted under any circumstances to be disclosed or distributed to third parties, unless otherwise is provided by the current Law.

6.3. Should be any inaccurate personal data detected the User himself can update it by sending a notification to the Operator via e-mail to marked "Updating personal data".

6.4. Personal data processing period is unlimited. User can at any time revoke his/her consent to personal data processing by sending a notification to the Operator via e-mail to marked "Revocation of consent to personal data processing".


7. Cross-border transfer of personal data

7.1. In case of cross-border transfer of personal data the Operator shall ensure the personal data is processed by a foreign state where it is sent to in accordance with the procedures of strong protection of rights of personal data subjects.

7.2. Cross-border transfer of personal data to a foreign state that do not comply with the above requirements can be carried out only if there is a written consent of the personal data subject to the cross-border transfer of his/her personal data and / or performance of a contract to which the personal data subject is a party.


8. Final clauses

8.1. User can receive any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator via e-mail:

8.2. This document shall reflect any changes and alterations to the personal data processing policy by the Operator. The policy remains in force indefinitely until it is replaced by a new version.

8.3. The current version of the Policy is freely available on the Internet at the URL address of the App.