CorpTime Privacy and Personal Data Processing Policy
1. INTRODUCTION1.1. This Privacy and Personal Data Processing Policy of the CorpTime Platform (hereinafter referred to as the ‘Privacy and Personal Data Processing Policy’) is a document that sets and defines the conditions for processing personal data of users of the Platform, including the CorpTime Platform and mobile applications named ‘CorpTime’, which is available on Google Play for the Android platform (at the following link
https://play.google.com/store/apps/details?id=pro.pt.app) and in the Apple Store for the iOS platform (via the link
https://apps.apple.com/ru/app/corptime/id6450563871) in the AppGallery for HarmonyOS platforms (via the link
https://appgallery.huawei.com/#/app/C110442827) (hereinafter referred to as ‘CorpTime’ or ‘Platform’), developed by KRUG Limited Liability Company (OGRN 1211600026769, TIN 1615016374), a legal entity established and operating in accordance with the legislation of the Russian Federation (hereinafter referred to as the Right Holder).
1.2. The Privacy and Personal Data Processing Policy is both a separate document and an integral part of the CorpTime User Agreement (hereinafter referred to as the ‘User Agreement’) for users who have accepted the User Agreement and continue to use CorpTime. The terms specified in the Privacy Policy are used in the meanings and definitions set out in both the Privacy Policy and the User Agreement. In case of contradictions between the provisions or meanings of the terms and definitions of the Privacy Policy and the User Agreement, the meanings of the terms and definitions of the Privacy Policy for the purposes of regulating the processing of personal data take precedence.
1.3. This Privacy and Personal Data Processing Policy applies only to the CorpTime Platform. It does not control and is not responsible for the resources of third parties to which the User can click on the links available on the Platform.
2. DEFINITIONS‘Rightholder’ – Limited Liability Company ‘KRUG’ (OGRN 1211600026769, TIN 1615016374), a legal entity established and operating in accordance with the legislation of the Russian Federation, with its registered office at: Russian Federation, 420500, Rep. Tatarstan, Verkhneuslonsky district, Innopolis, Universitetskaya str., 7, room 503, which grants the User the right to use the CorpTime Platform under the terms of the User Agreement.
‘User’ means a legally capable individual who, in accordance with the User Agreement, is granted the right to use the CorpTime Platform.
‘Account’ – a unique account created by the User on CorpTime and/or by them to access CorpTime.
‘Personal Page’ – a section of the CorpTime Platform that contains part of the information posted in the User's Account (including, at the User's request, photos), available for review by other Users. Access to the Personal Page may be restricted for other users within the limits of the Platform's available functionality.
‘Cookies’ are small text files that are placed on your computer, mobile device (such as a phone or smartphone, etc.), digital tablet or other device and contain information about your browsing history when you browse the CorpTime web Platform. They are processed and stored by your web browser. Cookies themselves are harmless and perform important functions for the CorpTime web Platform. Cookies are usually also easy to view and delete.
‘Device’ means any device that can access CorpTime, such as a computer, mobile device (such as a phone or smartphone, etc.), digital tablet, or other device.
‘Data’ (also ‘information’, ‘data’, ‘personal data’, ‘non-personal data’, ‘personally identifiable information’) – any information related to an identified or identifiable natural person (‘data subject’) - who can be identified directly or indirectly, in particular by reference to an identifier such as full name (pseudonym, unofficial designations), identification number, location data, occupation, gender, date of birth, photos, an email address, telephone number, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual; or technical and related information that does not allow identification of the individual, including, but not limited to, the type and version of the operating system, IP address in the technical parameters of the user's device, the origin and nature of detected malicious system threats.
‘Processing’ means any operation or set of operations that are performed with or without automated means, such as collecting, recording, organizing, structuring, storing, adapting or modifying, searching, consulting, using, disclosing by transmission, distribution or otherwise providing, aligning or combining, limiting, erasing or destruction.
‘Usage data’ refers to data that is collected automatically, either generated when using the CorpTime web Platform, or from the structure of the CorpTime web Platform itself (for example, the duration of a web page visit).
3. GENERAL PROVISIONS3.1. The Privacy and Personal Data Processing Policy defines the Copyright Holder's policy regarding the processing of CorpTime users' data.
3.2. The Privacy and Personal Data Processing Policy defines what data the Copyright Holder collects, uses, processes, discloses, transmits, stores and protects.
3.3. The User must fully read the Privacy Policy before using the CorpTime Platform and agree to all its articles. Using CorpTime and filling out any forms by the User means that the User fully and unconditionally agrees to the Privacy Policy. If the User does not fully accept and agree to the terms of the Privacy Policy, they must immediately stop using the Platform.
3.4. The privacy policy and processing of personal data is publicly available on the official CorpTime Platform of https://corptime.ru/confident_policy and in the mobile app specified in clause 1.1 of this Privacy Policy.
3.5. The Copyright Holder regularly reviews the Privacy Policy and makes changes to it for reasons related to methods, changes in the legislation of the Russian Federation, internal work and development of the Platform. The Copyright Holder places relevant updates on the Platform. We will notify you, at our sole discretion, of the addition and/or modification of the Privacy Policy in a manner that CorpTime deems most appropriate, and of any changes and amendments to the Privacy Policy through pop-ups and/or notifications on the Platform and / or by email. The User must acknowledge and comply with all changes to the Privacy Policy when using the Platform after the publication of these changes.
3.6. Using the Platform, including by downloading, installing, using the Platform and filling out any forms posted on it, means that the User unconditionally agrees to this Policy and the conditions for processing his data specified in it, the User confirms his consent to the processing of personal data by CorpTime and the Data provided and other information collected automatically data that is automatically transmitted services of the CorpTime Platform during their use using the software installed on the User's device, including the IP address, cookie data, information about the User's browser (or other program used to access the services), technical characteristics of the hardware and software used by the User, date and time of access to the services. services, addresses of the requested pages and other similar information, as well as voluntarily posted by the User on his personal page in the Account, including, but not limited to, content created by the User: comments, reviews, descriptions, improvements, design elements, photos, videos, images, drawings, audio files, links to third-party resources.
3.7. The User agrees that they must periodically review the Privacy Policy and become familiar with any changes to it.
4. PURPOSES OF DATA COLLECTION AND PROCESSING4.1. The CorpTime platform collects and stores only the personal information that is necessary for the provision of services or the execution of agreements and contracts with the User, except in cases where the law provides for mandatory storage of personal information for a period specified by law.
If you receive a notification from the User about the withdrawal of consent to the processing of personal data, the CorpTime Platform stops processing the User's personal data within a period not exceeding 10 business days from the date of receipt, and the User who revoked the consent must immediately stop using the Platform. The User (license) Agreement will be considered terminated on its own initiative from the moment such notification is sent.
Notification of revocation of consent to the processing of personal data is sent to the following email address: info@placetime.pro.
4.2. The CorpTime Platform processes the User's personal information for the following purposes:
4.2.1. Identification of the User registered on the CorpTime Platform.
4.2.2. Providing the User with access to personalized resources of the CorpTime Platform.
4.2.3. Establish feedback with the User, including sending notifications, requests related to the use of the CorpTime Platform, providing services, processing requests and requests from the User.
4.2.4. Determining the User's location to ensure security and prevent fraud.
4.2.5. Confirmation of the accuracy and completeness of the personal data provided by the User.
4.2.6. Sending notifications to Users of the CorpTime Platform.
4.2.7. Providing the User with effective customer and technical support in case of problems related to the use of the CorpTime Platform.
4.2.8. Performing advertising activities with the User's consent.
5. VOLUME OF PROCESSED DATA5.1. As part of the implementation of the Privacy Policy and User Agreement, the Copyright Holder stores and processes data to the required extent.
5.2. In the background and with the User's consent, the Copyright Holder stores and processes data that is automatically transmitted to the CorpTime Platform during its use by the software installed on the User's Device, including: IP address, information from cookies, information about the User's browser (or other program through which access to Platform objects is made), geolocation, access time, address of the requested page, as well as other data, including those provided by the User after registering the User (creating an Account) while using the Platform and Services.
5.3. The CorpTime platform, for its part, syncs search history, settings, and favorites in the user's account.
6. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA6.1. The processing of the User's personal data is carried out without any time limit in the following ways: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data, including in personal data information systems with the use of personal data. using automation tools or without using such tools. The processing of Users' personal data is carried out in accordance with Federal Law No. 152-FZ of 27.07.2006 ‘On Personal Data’.
6.2. The copyright holder has the right to:
perform any actions (operations) with the use of automation tools or without the use of automation tools with User Data, including collection, recording, copying, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access) to third parties, as well as in cases of disclosure at the request of state bodies (court requests, law enforcement agencies, etc.), in compliance with the requirements of confidentiality of information, depersonalization, blocking, deletion, or destruction of data;
use cookies and similar technologies (including: pixel tags, web beacons, transparent GIF files, JavaScript and local data storage, etc.) to collect personal identification information or information that may become personal identification information in combination with other information, in accordance with all necessary legal requirements regarding the confidentiality of User Data, identifying Users and their representatives when necessary. if applicable, by counting and sorting them at the sole discretion of the Copyright Holder and tracking which sections of the Platform they visit in order to provide the User with the maximum convenience of providing personalized information, remembering preferences in marketing and products, as well as assistance in obtaining the necessary information (including for entering certain blocks of the Platform or using an Account), analyzing actions A user on the CorpTime Platform, in order to improve and optimize the Services, including to make it easier for Users to find the necessary information;
provide advertising, messages and content, including by sending push notifications (messages) of the short message service (SMS), advertising notifications and messages, by e-mail on the Internet, using services and databases of both the CorpTime Platform itself and the services of third-party (external) services and resources on the Internet in full compliance with the rules of the General Data Protection Regulation (GDPR);
communicate directly with the User, including by phone.
6.3. The CorpTime Platform may use the information provided by the User, including Data, to ensure compliance with the requirements of applicable legislation (including to prevent and/or suppress illegal and/or illegal actions of Users).
6.4. Data is processed from the moment the User accepts the Privacy Policy and fills out the appropriate form for providing services on the Platform or providing Data in another form, and is stored until the purpose of processing is achieved or the relationship between the CorpTime Platform and the User is terminated as a result of deleting his account or revoking consent to data processing.
6.5. The Copyright Holder may transfer the User's personal information to third-party service providers when:
the User has agreed to such actions;
the user has independently and openly shared their information with other Users, including by publishing user content or by selecting the ‘visibility for all’ function;
the transfer is required to use a certain function/service of the Platform and the User is notified of this transfer and has accepted it or given an appropriate order;
transfer is provided for by the current legislation within the limits and for the purposes of the procedure established by law;
the transfer takes place as part of a sale or other transfer of rights to the Platform (in whole or in part), and all obligations to comply with the terms of the Privacy Policy regarding the information received by the acquirer pass to the acquirer.
6.6. The Copyright Holder will not sell, rent or disclose Data to third parties for marketing purposes without first obtaining the User's permission, except as provided in Section 7 of this Privacy Policy.
6.7. Access to User Data is possible within the Platform and from employees of the Copyright Holder.
6.8. The Copyright Holder will make all reasonable efforts to ensure that:
Information about Users, including their Personal Data, was collected on the CorpTime Platform only to the extent necessary to provide it.
the data is used exclusively for the purposes specified for their collection.
User information is not passed on to third parties and is not disclosed, except in cases specified in the Privacy Policy or applicable law.
6.9. CorpTime stores Data and protects it from unauthorized access and distribution in accordance with internal rules and policies. The User's data is subject to secrecy, except in cases specified in the Privacy Policy.
6.10. The User's data is subject to secrecy, except in cases when the User voluntarily provides information about himself or on his own behalf for public access.
6.11. According to Part 5 of Article 18 of Federal Law No. 152-FZ of 27.07.2006 ‘On Personal Data’, data of citizens of the Russian Federation is stored on servers located on the territory of the Russian Federation. If Data is deleted from the Platform for any reason and/or the User's Account, the corresponding Data will be immediately deleted in full.
6.12. Data is destroyed by erasing the information by certified software with guaranteed destruction (in accordance with the specified characteristics for the installed software with guaranteed destruction).
6.13. User Data is stored exclusively on servers and processed using automated systems, except in cases where non-automated data processing is necessary due to compliance with the requirements of applicable legislation.
6.14. The User agrees that any works posted (uploaded) by them within the framework of the Platform may be used by CorpTime on the CorpTime services as part of the Platform and resources, as well as in advertising or marketing materials posted on the CorpTime resources on the Internet to attract the attention of other Users to the Services or to other CorpTime resources and services, as with the User's full name (the full name (nickname, unofficial designation)will be specified) The User specified during Account registration) and without it, without the need to obtain special permission from the User and without paying royalties. If the User does not have the right to grant CorpTime the right to use any image or other work in the above-mentioned ways, he must refuse to post such images or works on the Platform. The user who posted an image in violation of this rule undertakes to reimburse the Copyright Holder for all costs and losses incurred by the copyright holder in connection with such placement.
6.15. The CorpTime Platform and the Copyright Holder will take all reasonably necessary steps to ensure the safe handling of personal data and data in accordance with the Privacy Policy, and the transfer of personal information will not be carried out to any organization or country, except in cases established by the Laws of the Russian Federation.
7. COOKIES AND OTHER TRACKING TECHNOLOGIES7.1. When a User enters the Platform, the Copyright Holder can automatically collect certain information from them using cookies or similar technologies and save it.
7.2. Cookies are text files placed on the User's device to collect standard Internet log information and information about user behavior. The Platform uses a cookie to identify the User's session and to synchronize the User's responses to one form with other corresponding forms.
7.3. Cookies allow the Platform to identify a specific User's Device
7.4. The Copyright holder collects and processes cookies in relation to Users
7.5. The Copyright Holder uses cookies in various ways to improve the CorpTime Platform, including for:
understanding how the User uses the Platform;
setting the User's preferences;
definitions of content, parameters, or functions that are specific to a particular User.
7.6. Cookies are processed by the Rightholder exclusively for the purpose specified in section 4 of this Privacy Policy, under the conditions and in the manner defined by this Privacy Policy, in particular on the basis of data obtained through cookies, the Rightholder develops the most useful functionality for the Platform available to the User, conducts statistical research, corrects errors in the Platform and tests new features to improve Platform performance, personalize them and show the most relevant information for the User.
7.7. The Platform processes the following categories of personal data of Platform users: last name, first name; contact phone number, email address; cookies; IP (without the ability to work with IP addresses in statistics); information collected through Yandex.Metrica metric programs; other personal data necessary to achieve the purpose of personal data processing, collection of personal data from the user's personal account. which is carried out in the presence and taking into account the legal grounds for processing personal data.
7.8. The Platform processes statistical and other data about the Platform user, including using Yandex.Metrica systems. Processing may also be entrusted to third parties to conduct research, perform work, or provide services. The Site user can manage cookies independently by changing the browser settings. Changes to user settings that result in cookies being blocked or deleted may make certain components of the Platform unavailable. These files contain information that allows you to identify the user when you visit the Platform again, and also store separate information about the user's actions, which allows you to display the Platform in accordance with the user's preferences.
7.9. Information collected using cookies placed on the User's device can be transferred and made available to the Copyright Holder and/or third parties who participate in the provision of services related to the placement and display of information to users (including offers relevant to the interests of users) in programs, products or services that belong to such persons or they are controlled by them (for example, site and app owners, advertising networks and other individuals, etc.), as well as companies that own Yandex.Metrica web analytics services. The use of information collected by cookies outside the Social Network site for advertising purposes, if any, may be subject to separate user agreements available on the websites and Platform of the Copyright Holder or third parties. The copyright holder and/or third parties may also provide the User with the opportunity to opt out of personalization of advertising, which may be subject to the regulation of legislation and rules applicable to such products and offers.
7.10. The user can opt out of processing cookies in the settings of their browser. In this case, the Social Network site will use only those cookies that are strictly necessary for the operation of the site and the provision of its functionality.
7.11. For more information about the cookies that the Platform uses, please refer to the CorpTime Cookie Policy at the following link:
https://corptime.ae/cookies_policy.
8. DATA STORAGE AND PROTECTION8.1. The Copyright Holder takes appropriate technical and organizational measures to ensure the security of Data from unauthorized or illegal use or accidental loss or destruction, alteration or unauthorized modification, disclosure or access, as well as from all other illegal forms of processing.
8.2. The copyright holder warns the User that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee its absolute security.
8.3. Copyright holder:
Uses secure servers for data storage.
Verifies the identity of any person requesting access to information before granting them access to the information;
Uses encryption technologies.
8.4. When protecting User data, the Copyright Holder relies on the following privacy principles:
Within the Platform, Data access should be restricted to a group of employees who deal with compliance and identity verification issues. All employees of the Copyright Holder are subject to complete confidentiality, and any subcontractors and sub-processors must sign a confidentiality agreement, unless complete confidentiality is part of the main agreement between the parties. Whenever information is accessed by an authorized employee, access is only possible through an encrypted connection. When accessing information in the database, the IP number of the person accessing the data must be pre-authorized to gain access. Any device used to access your personal data is protected when you log in to the system and has a corporate antivirus solution from your Service Provider installed on it. All local devices that temporarily store personal data are always locked in a secure room, unless they are not actively used or moved under continuous surveillance. Your data is never stored on mobile media such as USB sticks and DVDs.
The copyright Holder will inform Users about changes in the privacy and data security protection processes, including methods and policies.
Any access to data is blocked by default. Access to the Data is granted only to individually authorized employees, who are granted minimal access as needed.
The copyright holder uses security reports to track access patterns and proactively identify and eliminate potential threats. All administrative operations and access to the system are recorded to provide a control log in the event of unauthorized or accidental changes. Both internal and external monitoring services monitor system performance and availability.
9. RIGHTS AND OBLIGATIONS OF THE USER9.1. The User must:
9.1.1. Provide information about your personal data required to use the Platform.
9.1.2. Update or supplement the provided information about personal data in case of changes in this information.
9.2. The user has the following rights:
9.2.1. The right to request access to personal data, Data and information related to the use and processing of information specified in this subclause;
9.2.2. The right to request the CorpTime Platform to correct any Data that, in the User's opinion, is inaccurate. The user also has the right to request additional information that they consider incomplete. The User can change (update, supplement) all or part of the Data provided to them, as well as their privacy settings, at any time by using the edit function in the Account.
9.2.3. The right to request the Platform to delete your data under certain conditions.
9.2.4. The right to restrict the use of your Personal Data;
9.2.5. The right to object to the processing of your personal data for certain purposes;
9.2.6. The right to withdraw consent to the use of Data at any time.
9.3. All User requests and requests are processed by the platform within 30 business days.
10. FINAL PROVISIONS10.1. The Platform may contain links to services and other information resources of third parties on the Internet, posted solely for the convenience of Users. The CorpTime platform does not endorse or provide any assessment of third-party services or the information contained in these services, as well as possible results of their use, and does not verify the accuracy and relevance of the information provided. The User is fully responsible for the consequences of using the services mentioned in this paragraph.
10.2. This Policy applies only to the CorpTime Platform, and the Copyright Holder does not control and is not responsible for the services and offers of third parties that the User can access by clicking on external links available on the Platform, including the protection of data and information provided by the User to these third parties.
10.3. The User is solely responsible for the security (resistance to selection) of the funds chosen by him for accessing the Account, and also independently ensures their confidentiality. The User is solely responsible for all actions (as well as their consequences) within or using the functionality of the Service under the User's Account, including in cases where the User voluntarily transfers any data and Data for accessing the User's Account to third parties on any terms, including under contracts or agreements. At the same time, all actions within or using the Services on the Platform under the User's Account are considered to be performed by the User himself.
11. HOW TO CONTACT US11.1. If you have any questions about the Privacy Policy, the data we hold about you, or would like to exercise one of your data protection rights, please do not hesitate to contact us through the communication channels indicated on the Platform in the ‘Help’ and ‘Contact Us’ sections or to the following email addresses emails:
info@placetime.pro Contact person (Data Protection Officer): Andrey Bratyakin.
11.2. How we verify your identity. If and when you make a request for access to your data, we will attempt to verify your identity in order to use this information. If it is impossible to identify you from such information, or if we do not have enough information about you, we may require originals or certified copies of certain documentation to be able to verify your identity before we can grant you access to your information.