Privacy Policy

1. General Provisions

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (hereinafter — the Personal Data Law) and defines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by Enaza Apps LLC, OGRN 1195958008982 dated 14 March 2019, INN 5905059842, KPP 594801001 (hereinafter — the Operator).

1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of the individual and citizen when processing their personal data, including the protection of the rights to privacy and to personal and family confidentiality.

1.2. This Operator's policy regarding the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website https://cis.kleos.io.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data — the processing of personal data by means of computer technology.

2.2. Blocking of personal data — the temporary suspension of the processing of personal data (except where processing is necessary to clarify the personal data).

2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://cis.kleos.io.

2.4. Personal data information system — a collection of personal data contained in databases and the information technologies and technical means that ensure their processing.

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 by a specific User or other personal data subject.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

2.7. Operator — a state body, municipal body, legal entity, or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of the personal data to be processed, and the actions (operations) performed with the personal data.

2.8. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://cis.kleos.io.

2.9. Personal data permitted by the personal data subject for distribution — personal data to which access by an unlimited number of persons has been granted by the personal data subject by giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner provided for by the Personal Data Law (hereinafter — personal data permitted for distribution).

2.10. User — any visitor to the website https://cis.kleos.io.

2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific circle of persons.

2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including the disclosure of personal data in the mass media, posting in information and telecommunications networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data — any actions as a result of which personal data are irretrievably destroyed with the impossibility of further restoration of the content of the personal data in the personal data information system, and/or as a result of which the material carriers of personal data are destroyed.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:

• receive reliable information and/or documents containing personal data from the personal data subject;
• in the event that the personal data subject withdraws consent to the processing of personal data, as well as upon sending a request to cease the processing of personal data, continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided for by the Personal Data Law or other federal laws.

3.2. The Operator is obligated to:

• provide the personal data subject, at their request, with information concerning the processing of their personal data;
• organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
• respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• report to the authorized body for the protection of the rights of personal data subjects, at that body's request, the necessary information within 10 days from the date of receipt of such a request;
• publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;
• take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;
• cease the transfer (distribution, provision, access) of personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
• fulfill other obligations provided for by the Personal Data Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

• receive information concerning the processing of their personal data, except in cases provided for by federal laws. Such information is provided to the personal data subject by the Operator in an accessible form, and it must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• demand that the Operator clarify their personal data, block it, or destroy it if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, and to take measures provided for by law to protect their rights;
• put forward a condition of prior consent for the processing of personal data for the purpose of promoting goods, works, and services on the market;
• withdraw consent to the processing of personal data, as well as to send a request to cease the processing of personal data;
• appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in the processing of their personal data;
• exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obligated to:

• provide the Operator with reliable data about themselves;
• inform the Operator about the clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another personal data subject without the latter's consent, shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. The processing of personal data is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.

5.3. It is not permitted to combine databases containing personal data whose processing is carried out for purposes that are incompatible with one another.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and volume of the personal data processed correspond to the stated purposes of processing. The processed personal data must not be excessive in relation to the stated purposes of their processing.

5.6. When processing personal data, the accuracy of the personal data, their sufficiency, and, where necessary, their relevance to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data are stored in a form that allows the personal data subject to be identified for no longer than required by the purposes of processing the personal data, unless the storage period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. The processed personal data are destroyed or anonymized upon achievement of the purposes of processing or in the event of the loss of the need to achieve these purposes, unless otherwise provided for by federal law.

6. Purposes of Personal Data Processing

Purpose of processing: providing the User with access to the services, information, and/or materials contained on the website.

Personal data:

• surname, first name, patronymic;
• email address;
• telephone numbers;
• year, month, date, and place of birth.

Legal grounds:

• the Operator's statutory (constituent) documents;
• agreements concluded between the Operator and the personal data subject.

Types of personal data processing:

• collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data;
• sending informational emails to the email address.

7. Conditions for Personal Data Processing

7.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.

7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers, and duties assigned to the Operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for concluding an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be the beneficiary or guarantor.

7.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated thereby.

7.6. Processing is carried out of personal data to which access by an unlimited number of persons has been granted by the personal data subject or at their request (hereinafter — publicly available personal data).

7.7. Processing is carried out of personal data subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of the 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.

8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of the current legislation, or in the event that the personal data subject has given the Operator consent to transfer the data to a third party for the fulfillment of obligations under a civil-law agreement.

8.3. In the event that inaccuracies are identified in the personal data, the User may update them independently by sending the Operator a notice to the Operator's email address ea@kleos.io marked "Updating of personal data".

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by an agreement or the current legislation.

The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notice via email to the Operator's email address ea@kleos.io marked "Withdrawal of consent to the processing of personal data".

8.5. All information collected by third-party services, including payment systems, communication facilities, and other service providers, is stored and processed by such persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is responsible for familiarizing themselves with the said documents. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.

8.6. The prohibitions established by the personal data subject on the transfer (other than the provision of access), as well as on the processing or conditions of processing (other than obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator ensures the confidentiality of the personal data.

8.8. The Operator stores personal data in a form that allows the personal data subject to be identified for no longer than required by the purposes of processing the personal data, unless the storage period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.

8.9. The processing of personal data may be ceased upon the achievement of the purposes of processing, the expiration of the personal data subject's consent, the withdrawal of consent by the personal data subject, a request to cease the processing of personal data, or the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Personal Data Obtained

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transfer of the obtained information over information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator is obligated to notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out the cross-border transfer of personal data (such notice is sent separately from the notice of intent to process personal data).

10.2. Before submitting the above-mentioned notice, the Operator is obligated to obtain the relevant information from the authorities of the foreign state, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obligated not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided for by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Operator via email at ea@kleos.io.

12.2. This document will reflect any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the internet at https://cis.kleos.io/privacy-policy