Privacy policy of Site Users personal data https://sigfoxrussia.com/

Contents.

1. General Provisions

2. Definitions

3. Purpose of processing personal data

4. The types of data processed by Sigfox Russia

5. Processing, transfer and storage of personal data

6. Term of processing personal data

7. Final provisions



1. General Provisions

1.1. This Privacy policy of Site Users personal data (hereinafter - the Policy) defines the goals and procedure for processing personal data and measures to ensure the security of information that Energo Capital LLC can receive about the Site User https://sigfoxrussia.com/ (hereinafter - " Users "), as well as sites in the domain from any device and in communication with the Company in any form. Energo Capital LLC is entitled to use the Sigfox Russia trademark in accordance with the licensing agreement with Sigfox SA, a legal entity registered in the French Republic.



1.2. The Policy was developed in accordance with the provisions of the Federal Law of July 27, 2006 No. 152-ФЗ "On Personal Data", other legislative and regulatory legal acts that determine the procedure for working with personal data and the requirements for ensuring their safety.

1.3. Processing of personal data is carried out by Energo Capital LLC (hereinafter referred to as "Sigfox Russia") taking into account the need to protect the rights and freedoms of Users, including protecting the right to privacy, personal and family secrets, based on the following principles:

-processing of personal data is carried out on a legal and fair basis;

-processing of personal data is limited to the achievement of specific, predetermined and legitimate goals;

- personal data processing incompatible with the purposes of collecting personal data is not allowed;

- it is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other;

-Processing is subject only to personal data that meets the goals of their processing;

- the content and volume of the processed personal data corresponds to the declared processing goals. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed;

- the processed personal data is destroyed or depersonalized when the processing goals are achieved or if the need to achieve these goals is lost, unless otherwise provided by federal laws.



2. Definitions.

2.1. For the purposes of this Policy, the following basic definitions are used:

1) personal data - any information relating directly or indirectly to a defined or determined individual (subject of personal data);

2) operator - a state body, municipal body, legal or natural person, independently or jointly with other persons, organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) committed with personal data;

3) personal data processing - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

4) distribution of personal data - actions aimed at the disclosure of personal data to an indefinite number of persons;

5) provision of personal data - actions aimed at disclosing personal data to a specific person or a certain circle of persons;

6) blocking of personal data - a temporary cessation of the processing of personal data (unless the processing is necessary to clarify personal data);

7) destruction of personal data - actions, as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed;

8) depersonalization of personal data - actions, as a result of which it becomes impossible without the use of additional information to determine the ownership of personal data to a specific person.

9) cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to the authority of a foreign state, to a foreign individual or to a foreign legal entity.

10) Cookies are small text files in which the browser writes data from the websites visited.



2.2. Persons whose personal data are subject to processing by the Sigfox Russia:

• unregistered Users of the site https://sigfoxrussia.com/ (hereinafter referred to as the site) on the Internet.

• Users who leave a request for feedback on the Site.



3. Purpose of processing personal data

3.1. The purpose of the Privacy is to ensure the protection of the rights and freedoms of man and citizen in the processing of his personal data, including the protection of rights to privacy, personal and family secrets, strict and rigorous compliance with the requirements of the legislation of the Russian Federation and international treaties of the Russian Federation in the field of personal data, including:

1) providing the User with information about Sigfox Russia and the services provided;

2) familiarization of the User with the documents of Sigfox Russia;

3) establishing feedback, including sending notifications, requests regarding the provision of services, processing requests and applications from the User;

4) determining the location of the User to ensure security, prevent fraud;

5) providing the User with access to the sites or services of partners of the Company in order to obtain products, updates and services;

6) other purposes with the consent of the User.



4. The types of data processed by Sigfox Russia

1) surname, name, patronymic (including new surname, name, patronymic if changed);

2) gender;

3) place of work

4) position at the place of work, profession

5) contact phone number or information about other communication methods, including email address (at the place of work or personal)

6) other personal information that the User voluntarily provides to Sigfox Russia when it leaves an application on the site, uses the Site or otherwise contacts Sigfox Russia;

7) other personal data necessary to achieve the goals stipulated by clause 1.3 and section 3 of the Policy.



5. Processing, transfer and storage of personal data.

5.1. Sigfox Russia processes personal data by the method of collecting, organizing, accumulating, storing, updating (updating, changing), using, distributing (including transferring), depersonalizing, blocking, destroying. Processing of personal data with the consent of the subject of personal data to the processing of his personal data.

5.2. Sigfox Russia processes your personal data:

1) when registering online or placing a request / order for any of our products or services;

2) when filling out the feedback form on the site

3) through automatic processing by the device from which the site is logged in and which receives and transmits signals.

4) by any legal means, including in personal data information systems using automation tools or without using such tools.

5.3. The security of personal data processed by Sigfox Russia 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.

5.4. Sigfox Russia ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons. The User's personal data is not transferred to third parties, with the exception of cases related to the implementation of applicable law.

5.5. Sigfox Russia does not provide cross-border data transfer. If Sigfox Russia plans to carry out cross-border data transfer, then before starting the cross-border transfer of personal data, Sigfox Russia must make sure that the foreign state in whose territory it is supposed to transfer personal data provides reliable protection of the rights of personal data subjects. Cross-border transfer of personal data on the territory of foreign states that do not meet 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 personal data and / or the execution of the contract to which the personal data subject is a party.



6. Term of processing personal data

6.1. The user decides to provide his personal data and agrees to the processing of his personal data freely, by his own will and in his interest for the entire period necessary for Sigfox Russia to achieve the processing goals. The user has the right at any time to withdraw consent to the processing of his personal data by sending a written application to the address: of 21, fl. 12, bld. 6, Presnenskaya embankment, Moscow, 123112.

7. Cookies

7.1. Sigfox Russia uses the following types of cookies:

A) Session cookies (they store the session ID of the User. A cookie is set when the User logs in and is used to restore the session without entering personal data);

B) Other cookies

These cookies collect the User's network identifiers, including cookie identifiers, Internet protocol addresses and device identifiers; customer identifiers and sending data to Google Analytics about the device and actions of the User. Tracks Users through devices and marketing channels.



More information is available at the links:

• http://www.google.com/intl/en/privacy.html

• https://www.google.com/intl/en/policies/terms/

• https://policies.google.com/privacy?hl=en

• allaboutcookies.org.

7.2. Using the Site, the User agrees that Sigfox Russia may use statistics and cookies for their subsequent processing by Google Analytics, Yandex.Metrica, Google Firebase, Appmetrica, myTracker and may transfer it to a third party for research, performance of work or provision of services on behalf of Sigfox Russia.

7.3. Manage your cookie settings

7.3.1. The user can change the security settings of the web browser so that the device does not receive and save cookies or allows you to receive and store cookies from the websites selected by the User. The user can also select the option to receive a notification before receiving cookies.

7.3.2. The user can delete cookies stored by the browser at any time. Information stored in such cookies will be deleted from the device. However, these settings may adversely affect the usability of the Site.



8. Final provisions.

8.1. This website may contain links to other websites that are provided solely for the convenience of Users and are not a recommendation of the contents of these sites from Sigfox Russia.

8.2. The user has the right to exercise the rights stipulated by the legislation of the Russian Federation on personal data, including:

• clarify, update their personal data, demand their blocking or destruction;

• request from the Company a list of processed personal data, legal grounds for processing, sources of their receipt, information on the processing and storage periods, as well as other information related to the processing of their personal data.

8.3. The situation can be changed by issuing an update or a new edition, while an update or a new edition is mandatory for posting on the Site.