2.1. Administration determines for each purpose of Personal Data processing the categories and list of processed Personal Data, methods, terms of their processing and storage, the order of destruction of Personal Data upon achievement of the purposes of their processing or upon occurrence of other legal grounds.
2.2. The Administration has determined the following purposes of Personal Data processing:
2.2.1. For the User's Personal Data:
1) providing access to the Platform (registration);
2) ensuring the security of the Platform and its correct functioning;
3) restoring access to the Account (if it was stolen / login and password was lost / login error during registration / it is not possible to use two-factor authentication);
4) providing access within the framework of paid tariffs when paying by a bank card;
5) ensuring the reliability of the Platform and the ability to recover data after failures using backup and data recovery technologies;
6) processing on behalf of the User for the implementation of processes automated by the User using the Platform (regulated by the
Data Processing Agreement);
7) transfer of the User’s Personal Data to another Controller when the User transfers their profile to it.
2.2.2. For Personal Data of persons who address the Administration with various requests:
1) reviewing requests from
the Subjects of Personal Datare garding the processing of their Personal Data by Users on the Platform;
2) reviewing requests concerning violations of intellectual property rights by Users under the
Intellectual Property Protection Policy;
3) reviewing requests related to the posting of potentially inaccurate information about a business entity by Users;
4) consideration of questions regarding blocking of the account due to application to the Stripe payment system;5) reviewing other requests.
2.2.3. For Personal Data of individuals participating in the Administration’s informational projects — participation in the informational projects of the Administration.
2.2.4. For Personal Data of visitors to the Administration’s websites — analyzing website visitation statistics of the Administration.
2.3. The Administration processes Personal Data as described below:
2.3.1. The purpose of processing — to provide access to the Platform (registration)
Processed Personal Data:
- Name;
- Email;
- Unique identifier of the User used on the Platform (ID).
Processing is carried out automatically/with the User's participation:
- IP;
- City/Country (by IP);
- Browser Version;
- Language;
- UTM parameters;
- Partner Tag;
- The address of a website page's referrer;
- Cookie data used to identify the User without the use of technical measures.
Grounds for processing of Personal Data — processing shall be carried out as part of fulfillment of contractual obligations.
Types of processing of Personal Data:
- Collection, recording, systematization, accumulation, storage of Personal Data;
- Clarification (update, modification) is performed by the subject of Personal Data via the profile management form, as well as automatically during the User's interaction with the Website;
- De-identification, blocking, destruction of Personal Data is performed through the Control Panel for User management.
Retention period of Personal Data — Personal Data shall be stored for the entire duration of the agreement/during the periods established by the current United Arab Emirates legislation.
Deletion of Personal Data — Personal Data are deleted by the User in the
Personal Account or automatically at the end of the storage period for the data collected in automatic mode. The fact of deletion is recorded in the Platform logs.
2.3.2. The purpose of processing — to ensure the security of the Platform and its correct functioning
Processed Personal Data:
- Phone number;
- Links to the account owner's social media profiles.
Grounds for processing of Personal Data — processing is performed within the framework of fulfillment of contractual obligations.
Types of processing of Personal Data:
- Collection, recording, systematization, accumulation, storage (if fraudulent activities, spam or mass registration are suspected, the User shall provide the Administration with a contact phone number to confirm independent actions in the Personal Account);
- Viewing, depersonalization, blocking through the Control panel for user management.
Retention period of Personal Data — Personal Data shall be stored during the entire term of the agreement/during the periods established by the current United Arab Emirates legislation.
Deletion of Personal Data — Personal Data are deleted by the User in the
Personal Account. The fact of deletion is recorded in the Platform logs and stored for the period of time specified by the current legislation of the United Arab Emirates.
2.3.3. The purpose of processing — to restore access to the Account (if it has been stolen/lost login and password/error in login during registration/no possibility to use two-factor authentication)
Processed Personal Data:
- Masked bank card number;
- Phone number.
Grounds for processing of Personal Data — processing is performed within the framework of fulfillment of contractual obligations.
Types of processing of Personal Data:
- Collection, recording, accumulation, storage, depersonalization, blocking, deletion;
- Viewing through the Control Panel for user management.
Retention period of Personal Data — Personal Data shall be stored for the entire duration of the agreement.
Deletion of Personal Data — Personal Data are deleted by the Administration after the goal is achieved.
2.3.4. The purpose of processing — to ensure the reliability of the Platform operation and the possibility of data recovery after failures using data backup and recovery technologies
Processed Personal Data — all data processed by the Administration and listed in this document.
Grounds for processing of Personal Data — processing is carried out within the framework of fulfillment of contractual obligations.
Types of processing of Personal Data:
- Storage;
- Transfer for realization of geo-distributed storage of backup copies;
- Deletion is performed automatically upon expiration of the retention period of the backup copies of the data
Processing shall be carried out by hosting the Platform on the facilities leased by the Processor in data processing centres provided by partners with whom agreements have been concluded to guarantee the security of the Personal Data processed by them:
Retention period of Personal Data — Personal Data shall be stored for the entire term of the agreement/for the terms established by the applicable laws of the United Arab Emirates.
Deletion of Personal Data — Personal Data is deleted automatically upon expiration of the retention period of the backup copies of the data, as part of the backup and recovery process in place.
2.3.5. Purpose of processing — granting access within the framework of paid plans when paying by bank card
Processed Personal Data:
- Surname and first name on the card;
- Masked bank card number;
- Card validity period;
- Eemail;
- User ID;
- Information about the completed purchase (tariff name, price, currency);
- Ttransaction number;
- Invoice ID;
- Country of issue of the card;
- Unique card identifier (fingerprint).
Grounds for processing of Personal Data — processing is carried out within the framework of fulfillment of contractual obligations.
Types of processing of Personal Data:
- Receipt of Personal Data from third parties, recording, systematization, accumulation, storage of Personal Data is carried out after payment for the plans on the page;
- Clarification (update, modification) is not performed;
- Deletion, depersonalization, blocking, destruction of Personal Data is performed through the Control Panel for User management.
Retention period of Personal Data — Personal Data shall be stored for the entire term of the agreement/for the terms established by the applicable laws of the United Arab Emirates.
Deletion of Personal Data — Personal Data shall be deleted after the expiration of the retention period specified by the applicable laws of the United Arab Emirates.
Payment for the Plan, in accordance with which the User uses the services of the Platform, shall be carried out using the payment systems Stripe, Telr. These payment systems collect and store financial information in accordance with their user agreements and privacy policies.
The administration does not store full card details and does not process payments, receiving only a notification from the payment system about the fact of successful payment.
In the process of receiving payment for the Plan, the Administration may collect additional information related to the payment made by the User, including, but not limited to, the transaction number, time of the transaction, type and expiration date of the card used for payments, as well as the last four digits of the card number, name of the cardholder, country and city in which funds were written off from the card.
2.3.6. The purpose of processing — to transfer of the User’s Personal Data to another Personal Data Controller when the User transfers profile to it
Processed Personal Data:
- Name;
- Emai;.
- Unique User ID used on the Platform (ID).
Grounds for processing of Personal Data — processing is carried out as part of the User’s consent expressed by action.
Types of processing of Personal Data — cross-border transfer of Personal Data. Shall be initiated by the Personal Data Subject by instructing the Administration to transfer his/her Personal Data to another Personal Data Controller located in another jurisdiction. Carried out by the User independently by interacting with the Platform through the User interface.
Retention period of Personal Data — Within the framework of this processing of Personal Data, they are not store.
Deletion of Personal Data — deletion of Personal Data is not performed due to the fact that it is not stored.
2.3.7. The purpose of processing
— review of requests
from Personal Data Subjects regarding the processing of their Personal Data by Users on the PlatformProcessed Personal Data:For the applicant (Personal Data Subject):- Last name, first name;
- E-mail;
- Information about the identity document (including a scanned copy);
- Personal Data that is the subject of the request.
For the applicant’s representative:- Last name, first name;
- E-mail;
- Personal Data reflected in documents confirming the representative’s authority, processed exclusively for the purpose of reviewing the request submitted by the representative on behalf of the applicant (name, date of birth, address, and other data as required by applicable law for documents);
- Personal Data of the Personal Data Subject (the principal or represented person) whose Personal Data is the subject of the request.
Processing is carried out automatically upon submission of the request
via a web form:- IP address;
- City/Country (based on IP);
- Browser version;
- Language;
- UTM parameters;
- Partner tag;
- URL of the page the User came from when accessing the Platform;
- Cookie data used for User identification.
Grounds for processing of Personal Data
— processing is based on the consent of the Personal Data Subject.Types of processing of Personal Data:
- Collection, recording, accumulation, storage, anonymization, blocking, deletion.
- Viewing via the system for interaction with Users.
Retention period of Personal Data
— Personal Data shall be stored for 3 (three) years after the response to the request
.Deletion of Personal Data
— Personal Data are deleted by the Administration after the retention period or earlier if the consent for processing is withdrawn.2.3.8. The purpose of processing
— review of requests
regarding violations of intellectual property rights by Users within the Intellectual Property Protection PolicyProcessed Personal Data:For the applicant (rights holder):- Full name of the rights holder;
- E-mail;
- Information about the identity document (including a scanned copy).
For the applicant’s representative:- Last name, first name;
- E-mail;
- Personal Data reflected in documents confirming the representative’s authority, processed exclusively for the purpose of reviewing the request submitted by the representative on behalf of the applicant (name, date of birth, address, and other data as required by applicable law for documents);
- Job title and position (for representatives of legal entities authorized to act without a power of attorney).
- Full name of the rights holder (for individuals).
Processing is carried out automatically upon submission of the request
via a web form:- IP address;
- City/Country (based on IP);
- Browser version;
- Language;
- UTM parameters;
- Partner tag;
- URL of the page the User came from when accessing the Platform;
- Cookie data used for User identification.
Grounds for processing of Personal Data
— processing is based on the consent of the Personal Data Subject.Types of processing of Personal Data:
- Collection, recording, accumulation, storage, anonymization, blocking, deletion.
- Viewing via the system for interaction with Users.
Retention period of Personal Data
— Personal Data shall be stored for 3 (three) years after the response to the request
.Deletion of Personal Data
— Personal Data are deleted by the Administration after the retention period or earlier if the consent for processing is withdrawn.2.3.9. The purpose of processing
— review of requests
regarding the posting of potentially inaccurate information about a business entity by UsersProcessed Personal Data:For the applicant:- Last name, first name of the applicant (business entity);
- E-mail.
For the applicant’s representative:- Last name, first name;
- E-mail;
- Personal Data reflected in documents confirming the representative’s authority, processed exclusively for the purpose of reviewing the request submitted by the representative on behalf of the applicant (name, date of birth, address, and other data as required by applicable law for documents);
- Job title and position (for representatives of legal entities authorized to act without a power of attorney);
- Full name of the person represented (trustor) whose Personal Data is processed.
Processing is carried out automatically upon submission of the request
via a web form:- IP address;
- City/Country (based on IP);
- Browser version;
- Language;
- UTM parameters;
- Partner tag;
- URL of the page the User came from when accessing the Platform;
- Cookie data used for User identification.
Grounds for processing of Personal Data
— processing is based on the consent of the Personal Data Subject.Types of processing of Personal Data:
- Collection, recording, accumulation, storage, anonymization, blocking, deletion.
- Viewing via the system for interaction with Users.
- Transfer — data may be transferred to the User in relation to whom the request was submitted.
Retention period of Personal Data
— Personal Data shall be stored for 3 (three) years after the response to the request
.Deletion of Personal Data
— Personal Data are deleted by the Administration after the retention period or earlier if the consent for processing is withdrawn.2.3.10.The purpose of processing
— consideration of questions regarding blocking of the account due to application to the Stripe payment systemProcessed Personal Data:For the applicant:- Last name, first name of the applicant;
- E-mail.
For the owner of the payment instrument:
- Last name, first name of the payment instrument;
- E-mail;
- First name, last name indicated on the bank card from which the payment was made;
- First and last 4 digits of the bank card;
- Personal data contained in the document confirming the ownership of the bank card.
For the applicant’s representative:- Last name, first name;
- E-mail;
- Personal Data reflected in documents confirming the representative’s authority, processed exclusively for the purpose of reviewing the request submitted by the representative on behalf of the applicant (name, date of birth, address, and other data as required by applicable law for documents).
Processing is carried out automatically upon submission of the request
via a web form:- IP address;
- City/Country (based on IP);
- Browser version;
- Language;
- UTM parameters;
- Partner tag;
- URL of the page the User came from when accessing the Platform;
- Cookie data used for User identification.
Grounds for processing of Personal Data
— processing is based on the consent of the Personal Data Subject.Types of processing of Personal Data:
- Collection, recording, accumulation, storage, anonymization, blocking, deletion.
- Viewing via the system for interaction with Users.
- Transfer — data may be transferred to the User in relation to whom the request was submitted.
Retention period of Personal Data
— Personal Data shall be stored for 3 (three) years after the response to the request
.Deletion of Personal Data
— Personal Data are deleted by the Administration after the retention period or earlier if the consent for processing is withdrawn.2.3.11. The purpose of processing
— review of other requests
Processed Personal Data:For the applicant:- Last name, first name of the applicant;
- E-mail;
- Personal Data that is the subject of the request (if available in the request).
For the applicant’s representative:- Last name, first name;
- E-mail;
- Personal Data reflected in documents confirming the representative’s authority, processed exclusively for the purpose of reviewing the request submitted by the representative on behalf of the applicant (name, date of birth, address, and other data as required by applicable law for documents).
Processing is carried out automatically upon submission of the request
via a web form:- IP address;
- City/Country (based on IP);
- Browser version;
- Language;
- UTM parameters;
- Partner tag;
- URL of the page the User came from when accessing the Platform;
- Cookie data used for User identification.
Grounds for processing of Personal Data
— processing is based on the consent of the Personal Data Subject.Types of processing of Personal Data:
- Collection, recording, accumulation, storage, anonymization, blocking, deletion.
- Viewing via the system for interaction with Users.
- Transfer — data may be transferred to the User in relation to whom the request was submitted.
Retention period of Personal Data
— Personal Data shall be stored for 3 (three) years after the response to the request
.Deletion of Personal Data
— Personal Data are deleted by the Administration after the retention period or earlier if the consent for processing is withdrawn.2.3.12. Purpose of processing — participation in the Administration’s informational projects and informing about themProcessed Personal Data:- Participant’s name;
- E-mail;
- Messenger nickname.
Processing is carried out automatically upon submission of the request
via a web form:- IP address;
- City/Country (based on IP);
- Browser version;
- Language;
- UTM parameters;
- Partner tag;
- URL of the page the User came from when accessing the Platform;
- Cookie data used for User identification.
Grounds for processing of Personal Data
— processing is based on the consent of the Personal Data Subject.Types of processing of Personal Data:
- Collection, recording, accumulation, systematization, storage, extraction, use, anonymization, blocking, deletion.
- Clarification (updating, changing) is not performed.
Retention period of Personal Data
— Personal Datas shall be stored for 3 (three) years after registration for participation in the Administration’s informational project.Deletion of Personal Data
— Personal Data are deleted by the Administration after the retention period or earlier if the consent for processing is withdrawn.2.3.13. Purpose of processing — analysis of website visitation statistics of the AdministrationProcessing is carried out automatically upon visiting the Administration’s websites:- IP address;
- City/Country (based on IP);
- Browser version;
- Language;
- UTM parameters;
- Partner tag;
- URL of the page the User came from when accessing the Platform;
- Cookie data used for User identification.
Grounds for processing of Personal Data
— legitimate interest of the Administration.Types of processing of Personal Data:
- Collection, recording, accumulation, systematization, storage, extraction, use, anonymization, blocking, deletion.
- Clarification (updating, changing) is not performed.
Retention period of Personal Data
— Personal Data shall be stored for 3 (three) years after visiting the Administration’s website.Deletion of Personal Data
— Personal Data are deleted by the Administration after the retention period or earlier if the Personal Data Subject requests it.