Policy regarding the processing of personal data

Personal Data Processing and Storage Agreement

This User Agreement is a public offer (i.e., a proposal to conclude an agreement). By clicking the "Submit," "Request a Callback," "Subscribe," and any other data submission buttons, you are deemed to have accepted this agreement.
If you believe that this Agreement or the Site Administration infringes upon your rights, please notify us via email at: info@pocketkey.ru.
By providing their personal data, the User of the website http://pocketkey.ae (hereinafter referred to as the "Site") gives consent to the processing, storage, and use of their personal data pursuant to Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006, for the following purposes:

Provision of customer support;
Keeping the User informed about news, promotions, and special offers;
Conducting audits and other internal research to improve the quality of the services provided.

Personal data refers to any private information that allows for the identification of the Site User, such as:

First and Last Name
Contact Phone Number
Email Address

The Users' personal data is stored exclusively on electronic media and processed using automated systems, except for cases where non-automated processing of personal data is necessary to comply with legal requirements.
PocketKey Rus LLC undertakes not to transfer the received personal data to third parties, except in response to lawful requests from authorized bodies of state power of the Russian Federation, solely on the grounds and in accordance with the procedure established by the legislation of the Russian Federation.
PocketKey Rus LLC reserves the right to amend these rules unilaterally, provided that such amendments do not contravene the current legislation of the Russian Federation. The changes to the terms of these rules come into force after their publication on the Site.

Personal Data Processing Policy

1. General Provisions
This Personal Data Processing Policy is drafted in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (hereinafter referred to as the "Personal Data Law") and defines the procedure for processing personal data and the measures to ensure the security of personal data undertaken by PocketKey Rus LLC (hereinafter referred to as the "Operator").
1.1. The Operator's most important goals and conditions for its operations are the observance of human rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrecy.
1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about users of the website http://pocketkey.ae.
2. Basic Concepts Used in the Policy
2.1. Website – a set of graphical and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address http://pocketkey.ae.
2.2. Personal Data Information System – a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.3. Automated Processing of Personal Data – processing of personal data by means of computer technology.
2.4. Blocking of Personal Data – temporary cessation of personal data processing (except for cases where processing is necessary to clarify personal data).
2.5. Operator – a state body, municipal body, legal entity, or individual, independently or jointly with other persons, organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.6. Processing of Personal Data – any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Depersonalization of Personal Data – actions resulting in the impossibility to determine, without the use of additional information, the belonging of personal data to a specific User or other subject of personal data.
2.8. Personal Data – any information relating directly or indirectly to a specific or identifiable User of the website http://pocketkey.ae.
2.9. Personal Data, permitted by the subject of personal data for dissemination – personal data, access to which by an unlimited number of persons is provided by the subject of personal data by giving consent to the processing of personal data permitted for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data permitted for dissemination").
2.10. User – any individual accessing the Website via the Internet and using the website http://pocketkey.ae.
2.11. Provision of Personal Data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.
2.12. Dissemination of Personal Data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing an unlimited circle of persons with personal data, including the publication of personal data in mass media, posting in information and telecommunication networks, or providing access to personal data in any other way.
2.13. Destruction of Personal Data – any actions resulting in the irreversible destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of the material carriers of personal data.
2.14. Cross-Border Transfer of Personal Data – the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
3. Basic Rights and Obligations of the Operator
3.1. The Operator has the right to:

Receive from the subject of personal data reliable information and/or documents containing personal data;
Continue processing personal data without the subject's consent in the event of the subject's withdrawal of consent, 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 obligations under the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

Provide the subject of personal data, upon their request, with information regarding the processing of their personal data;
Process personal data in accordance with the procedure 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;
Provide the authorized body for the protection of the rights of personal data subjects with the necessary information within 30 days from the date of receipt of such a request;
Publish or otherwise provide unrestricted access to this Policy;
Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, 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;
Perform other duties provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:

Obtain information regarding the processing of their personal data, except in cases provided for by federal laws. The information is provided to the subject by the Operator in an accessible form and shall not contain personal data relating to other subjects, unless 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;
Require the operator to clarify, block, or destroy their personal data if the data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, and to take statutory measures to protect their rights;
Impose a condition of prior consent when processing personal data for the purpose of marketing goods and services;
Withdraw consent to 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 during the processing of their personal data;
Exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

Provide the Operator with reliable information about personal data necessary for using the Website;
Update, supplement the provided information about personal data in case of changes to this information.

4.3. Persons who have provided the Operator with inaccurate 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. Personal Data Processed by the Operator
5.1. Last name, First name.
5.2. Contact phone number.
5.3. Email address.
5.4. The site also collects and processes anonymized data about visitors (including "cookies") using internet statistics services (Yandex Metrica, Google Analytics, and others).
5.5. The data mentioned above are collectively referred to as "Personal Data" throughout this Policy.
5.6. The Operator does not process special categories of personal data concerning race, nationality, political opinions, religious or philosophical beliefs, or intimate life.
5.7. The processing of personal data permitted for dissemination, which falls under the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law, is permitted provided that the prohibitions and conditions set forth in Article 10.1 of the Personal Data Law are observed.
5.8. The User's consent to the processing of personal data permitted for dissemination is executed separately from other consents for the processing of their personal data. The conditions stipulated by Article 10.1 of the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.8.1 Consent to the processing of personal data permitted for dissemination is provided by the User directly to the Operator.
5.8.2 The Operator is obliged, no later than three business days from the receipt of the specified User consent, to publish information on the processing conditions, on the existence of prohibitions and conditions for processing by unlimited persons of personal data permitted for dissemination.
5.8.3 The transfer (distribution, provision, access) of personal data permitted by the subject for dissemination must be terminated at any time at the request of the subject. This request must include the last name, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request can only be processed by the Operator to whom it is addressed.
5.8.4 Consent to the processing of personal data permitted for dissemination ceases to be effective from the moment the Operator receives the request specified in clause 5.8.3 of this Policy.
6. Principles of Personal Data Processing
6.1. The processing of personal data is carried out on a lawful and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.
6.3. The merging of databases containing personal data processed for incompatible purposes is not allowed.
6.4. Only personal data that meets the purposes of their processing are subject to processing.
6.5. The content and volume of the processed personal data correspond to the stated purposes of processing. The processed personal data shall not be excessive in relation to the stated purposes of their processing.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of personal data processing are ensured. The Operator takes necessary measures and/or ensures their taking to remove or clarify incomplete or inaccurate data.
6.7. The storage of personal data is carried out in a form that allows the identification of the subject of personal data, no longer than required by the purposes of personal data processing, unless the storage period is established by federal law, a contract to which the subject is a party, beneficiary, or guarantor. Processed personal data are destroyed or anonymized upon achieving the processing purposes or in case of loss of necessity to achieve these purposes, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purposes of processing the User's personal data:
* Establishing feedback with the User, including sending notifications, inquiries regarding the use of the Website, provision of services, processing requests and applications from the User.
* Providing the User with effective customer support.
* Providing the User, with their consent, with special offers, pricing information, newsletters, and other information on behalf of the resource or on behalf of partners.
* Carrying out promotional activities with the User's consent.
* Conducting internal audits and compiling audience statistics based on the obtained data.
7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending the Operator an email to info@pocketkey.ru with the subject "Opt-out of notifications".
7.3. Anonymized User data collected using internet statistics services is used to collect information about User actions on the site, improve the quality of the site and its content.
8. Legal Grounds for Personal Data Processing
8.1. The legal grounds for the processing of personal data by the Operator are:
* Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006;
* Federal laws, other regulatory legal acts in the field of personal data protection;
* Users' consents to the processing of their personal data, to the processing of personal data permitted for dissemination.
8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the site https://pocketoffice.pro/ or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The Operator processes anonymized data about the User if it is allowed in the User's browser settings (saving "cookies" and using JavaScript technology are enabled).
8.4. The subject of personal data independently decides to provide their personal data and gives consent freely, willingly, and in their own interest.
9. Conditions for Personal Data Processing
9.1. The processing of personal data is carried out with the consent of the subject to the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or law, for the performance of functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. The processing of personal data is necessary for the performance of a contract to which the subject is a party, beneficiary, or guarantor, as well as for concluding a contract on the initiative of the subject or a contract under which the subject will be a beneficiary or guarantor.
9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for achieving socially important purposes, provided that the rights and freedoms of the subject are not violated.
9.6. Personal data is processed, access to which is provided by the subject or at their request (hereinafter – publicly available personal data).
9.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
10. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of 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.
10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
10.2. The User's personal data will under no circumstances be transferred to third parties, except in cases related to the execution of current legislation or if the subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
10.3. If inaccuracies in personal data are identified, the User can update them independently by sending a notification to the Operator's email address info@pocketkey.ru with the subject "Update of personal data".
10.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided by the contract or current legislation.
The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address info@pocketkey.ru with the subject "Withdrawal of consent to the processing of personal data".
10.5. All information collected by third-party services, including payment systems, communications means, and other service providers, is stored and processed by the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to independently familiarize themselves with the specified documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.6. The prohibitions established by the subject on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination, do not apply in cases of processing personal data in the state, public, and other public interests defined by the legislation of the RF.
10.7. The Operator ensures the confidentiality of personal data when processing them.
10.8. The Operator stores personal data in a form that allows the identification of the subject, for no longer than required by the purposes of processing, unless the storage period is set by federal law, a contract to which the subject is a party, beneficiary, or guarantor.
10.9. The condition for termination of personal data processing may be the achievement of the processing purposes, expiration of the subject's consent or withdrawal of consent by the subject, as well as the identification of unlawful processing of personal data.
11. List of Actions Performed by the Operator with the Received Personal Data
11.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
11.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or without it.
12. Cross-Border Transfer of Personal Data
12.1. Before commencing the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state, to whose territory the transfer is intended, provides reliable protection of the rights of personal data subjects.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements can only be carried out if the subject gives written consent to the cross-border transfer of their personal data and/or in performance of a contract to which the subject is a party.
13. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject, unless otherwise provided by federal law.
14. Final Provisions
14.1. The User can obtain any clarifications on questions regarding the processing of their personal data by contacting the Operator via email at info@pocketkey.ru.
14.2. 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.
14.3. The current version of the Policy is available online at http://pocketkey.ae.