Privacy Policy on personal data processing

1. Basic Terms

This personal data processing policy follows the requirements of law "About Personal Data" (hereinafter - the Law on Personal Data) and defines the order of personal data processing and measures to ensure the security of personal data, undertaken by Elly Analytics Inc. (hereinafter - the Operator).

1.1 The Operator makes its most important goal and condition of its activity the observance of human and citizen's rights and freedoms when processing their personal data, including the protection of rights to privacy, individual and family secrets.

1.2 The present Policy of the Operator regarding the processing of personal data (hereinafter - the Policy) applies to all information that the Operator can obtain about the visitors of websites belonging to the Operator's clients.

2. Basic concepts used in this Policy

2.1 Automated processing of personal data means processing personal data using computer equipment.

2.2 Blocking personal data means temporary termination of processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3 Website means a set of graphic and informational materials and computer programs and databases, ensuring their availability on the Internet at a network address.

2.4 Personal Data Information System - an aggregate of personal data contained in databases of personal data and information technology and technical means ensuring their processing.

2.5 Anonymization of personal data - actions, as a result of which it is impossible to determine, without using additional information, whether the personal data belongs to a particular User or another subject of personal data.

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

2.7 Operator - a state body, municipal authority, 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 purpose of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8 Personal data - any information relating directly or indirectly to a specific or identifiable website user https://ellyanalytics.com.

2.9. Personal data, authorized by the subject of personal data for distribution - personal data, access to which is provided by the subject of personal data by giving consent to the processing of personal data, authorized by the subject of personal data for distribution in the manner prescribed by law on personal data (hereinafter - personal data, authorized for distribution).

2.10. User - any visitor to the https://ellyanalytics.com website.

2.11. Provision of personal data - actions aimed at disclosing personal data to a particular person or a specific circle of people.

2.12. Dissemination of personal data - any action aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or to familiarize the general public with personal data, including publication of personal data in the media, placement in information and telecommunications networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data - 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 resulting from which personal data is destroyed irretrievably with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) destroyed material media of personal data.

2.15. Operator's Client - a state body, municipal authority, legal entity, or individual to whom the Operator provides marketing analytics services on a contractual basis. Each Client has their Websites.

3. Basic rights and obligations of the Operator

3.1 The Operator has the right:
— receive from the subject of personal data either reliable information or documents containing personal data;
— In case the personal data subject withdraws their consent to the processing of personal data, the Operator has the right to continue the processing of personal data without the permission of the personal data subject on the grounds specified in the Personal Data Law;
— Independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of obligations stipulated by the Personal Data Law and regulatory legal acts adopted following it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2 The operator shall:
— Provide to the subject of personal data, at their request, information relating to the processing of their data;
— Organize personal data processing in the manner prescribed by applicable laws;
— to respond to requests and inquiries of subjects of personal data and their legal representatives, following the requirements of the Law on Personal Data;
— to provide the authorized body for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 30 days from the date of receipt of such a request;
— Publish or otherwise ensure unrestricted access to this Policy on personal data processing
— Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other illegal actions concerning personal data
— Cease the transfer (distribution, provision, access) of personal data, cease processing and destroying personal data in the manner and cases provided by the Personal Data Law
— Perform other duties provided by the Personal Data Law.

4. Basic rights and obligations of subjects of personal data

4.1 Personal data subjects have the right:
- To receive information relating to the processing of their personal data, except in cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form. It must not contain personal data relating to other personal data subjects, except in cases where there are legitimate grounds for disclosure of such personal data. The Personal Data Law establishes the list of information and the procedure for obtaining it;
- to require the Operator to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as to take statutory measures to protect their rights;
- to put forward the condition of prior consent when processing personal data to promote goods, works, and services on the market
- to withdraw the consent to the processing of personal data;
- To complain to the authorized body for protection of the rights of subjects of personal data or in court against unlawful acts or omissions of the Operator in the processing of his personal data
- To exercise other rights provided for by the legislation.

4.2 Subjects of personal data must:
- provide the Operator with reliable data about themselves;
- Notify the Operator of the clarification (updating, modification) of their personal data.

4.3 Persons who provided the Operator with inaccurate information about themselves, or information about another subject of personal data without the latter's consent, shall be liable under the laws.

5. The Operator may process the following personal data of the User

5.1 E-mail address.

5.2. Phone numbers.

5.3. Google ClientID of the User of the site.

5.4 The site also collects and processes visitors anonymized data (including cookies) using Internet statistics services (Google Analytics, and others).

5.5 The data mentioned above are further combined in the text of this Policy with the general concept of Personal Data.

5.6 The Operator does not process special categories of personal data relating to race, ethnicity, political views, religious or philosophical beliefs, or intimate life.

5.7 Processing of personal data, allowed for dissemination, from among special categories of personal data, specified in Part 1 of Article 10 of the Personal Data Law, is permitted if the prohibitions and conditions stipulated by 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 shall be executed separately from other permissions to processing their personal data. In this case, the conditions stipulated, in particular, by Article 10.1 of the Personal Data Law shall be observed. The competent authority shall establish the requirements for the content of such consent to protect personal data subjects' rights.

5.8.1 The User provides the consent to the processing of the personal data directly to the Operator.

5.8.2 The Operator is obliged within three working days from the receipt of the above consent of the User to publish information about the conditions of processing, the existence of prohibitions and requirements on the processing of personal data allowed for distribution to an unlimited number of persons.

5.8.3 Transfer (distribution, provision, access) of personal data, authorized by the subject of personal data for distribution, must be terminated at any time at the request of the subject of personal data. This requirement must include the last name, first name, patronymic (if any), contact information (phone number, e-mail address, or mailing address) of the subject of personal data, and a list of personal data whose processing is to be terminated. The personal data specified in this request may only be processed by the Operator to which it is sent.

5.8.4 Consent to the processing of personal data permitted for distribution shall cease from the moment of receipt by the Operator of the request specified in paragraph 5.8.3 of this Policy concerning the processing of personal data.

6. Principles of personal data processing

6.1 Processing of personal data shall be lawful and fair.

6.2 Processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes of personal data collection is not permitted.

6.3 Databases containing personal data, which are processed for purposes incompatible with each other, shall not be combined.

6.4 Only personal data that meets the purposes of processing shall be processed.

6.5 The content and scope of processed personal data shall comply with the stated processing purposes. Processed personal data shall not be excessive concerning the stated processing purposes.

6.6. When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, relevance concerning the purpose of personal data processing shall be ensured. Accordingly, the Operator shall take necessary measures or guarantee that they are taken to remove or clarify incomplete or inaccurate data.

6.7 Personal data shall be stored in a form that makes it possible to identify the subject of personal data, no longer than required by the purposes of personal data processing, unless the storage period of personal data is established by federal law, an agreement to which the subject of personal data is a party, a beneficiary or a guarantor. Processed personal data shall be destroyed or depersonalized upon attainment of processing objectives or if it is no longer necessary to attain such objectives unless otherwise provided for by federal law.

7. Purposes of personal data processing

7.1 The purpose of the processing of personal data of the User:
- Analysis of data to manage the advertising activity of the company.

7.2 The Operator also has the right to send the User notifications about new products and services, special offers, and different events. However, the User can always refuse to receive information messages by e-mailing the Operator at services-elly@ellyanalytics.com with the note "Refuse notifications about new products and services and special offers."

7.3 The anonymized data of Users, collected with the help of Internet statistics services, serves for collecting information about Users' actions on the site, improving the quality of the site and its content.

8. Legal basis for the processing of personal data

8.1 The legal basis for the processing of personal data by the Operator is:
- Federal Laws, other regulatory legal acts in the sphere of personal data protection;
- The User's consent to the processing of personal data and the processing of personal data allowed for distribution.

8.2. The Operator processes the User's personal data only if the User fills them in or sends them independently through the special forms located on the websites of the Operator's clients or sent to the Operator by email. By filling out the relevant forms or sending his personal data to the Operator, the User expresses his consent to this Policy.

8.3. The Operator processes the depersonalized data about the User if it's allowed in the settings of the User's browser (the saving of "cookie" files and the use of JavaScript technology is enabled).

8.4 The subject of personal data independently decides to provide his personal data and gives his consent freely, willingly, and in his interest.

9. Terms of personal data processing

9.1 Personal data processing is carried out with the subject's data consent to process his personal data.

9.2 Personal data processing is necessary to achieve the purposes provided for by an international treaty or by law, to perform the functions, powers, and duties imposed on the Operator by the legislation.

9.3 Personal data processing is necessary for the administration of justice, execution of a judicial act, or an act of another body or official to be executed under the legislation on enforcement proceedings.

9.4 Personal data processing is necessary to perform the contract, party or beneficiary, or guarantor of which is the subject of personal data, as well as for the conclusion of the contract on the initiative of the subject of personal data or the contract under which the subject of personal data will be a beneficiary or guarantor.

9.5 Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially important goals, provided that this does not violate the rights and freedoms of the subject of personal data.

9.6 Personal data processing, access to which is granted to an unlimited number of persons by the subject of personal data or at their request (hereinafter - publicly accessible personal data).

9.7 Personal data processing is subject to publication or mandatory disclosure under federal law.

10. Procedure for collection, storage, transfer, and other processing of personal data

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully meet the requirements of current legislation on personal data protection.

10.1 The Operator provides safety of personal data and takes all possible measures that exclude unauthorized persons' access to personal data.

10.2 The personal data of the User shall never, under no circumstances, be transferred to third parties, except in cases related to the implementation of the current legislation or if the subject of personal data has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil law contract.

10.3. In case of identifying inaccuracies in personal data, the User may update them independently by sending a notice to the Operator's e-mail address services-elly@ellyanalytics.com with a note "Updating of personal data."

10.4 The term personal data processing is determined by achieving the purposes for collecting the personal data unless a different term is stipulated by the contract or by applicable law. The User may withdraw their consent to the processing of personal data at any time by contacting the Operator by email at services-elly@ellyanalytics.com, marked "Withdrawal of consent to the processing of personal data."

10.5 All information collected by third-party services, including payment systems, means of communication, and other service providers, is stored and processed by the specified persons (Operators) according to their User Agreement and Privacy Policy. The subject of personal data or the User is obliged to promptly get acquainted with the selected documents. The Operator shall not be liable for the actions of third parties, including the service providers mentioned in this clause.

10.6 The prohibitions established by the personal data subject on the transfer (other than granting access), as well as on the processing or processing conditions (other than gaining access) of personal data permitted for distribution shall not apply in cases of processing of personal data in the state, public, and other public interests as defined by legislation.

10.7 The Operator shall ensure the confidentiality of personal data when processing personal data.

10.8 The Operator shall store personal data in a form that makes it possible to identify the subject of personal data no longer than required by the purposes of personal data processing unless the period of personal data storage is established by federal law, a contract to which the subject of personal data is a party, a beneficiary or a guarantor.

10.9 A condition for termination of personal data processing may be an achievement of personal data processing objectives, expiration of the personal data subject's consent or withdrawal of consent by the personal data subject, and detection of unlawful personal data processing.

11. The list of actions performed by the Operator with the received personal data

11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes, and destroys personal data.

11.2 The Operator carries out automated processing of personal data with or without receiving or transmitting received information via information and telecommunications networks.

12. Trans-border transfer of personal data

12.1 Before a transborder transfer of personal data, the Operator shall ensure that the foreign country to the territory of which the transfer of personal data is intended provides reliable protection of personal data subjects' rights.

12.2 The transborder transfer of personal data to foreign countries, which do not meet the above requirements, may only occur if the personal data subject consents in writing to the transborder transfer of their personal data or fulfillment of the contract to which the personal data subject is a party.

13. Confidentiality of personal data

The Operator and other persons who obtained access to personal data must not disclose to third parties and not disseminate personal data without the consent of the subject of personal data unless otherwise provided by federal law.

14. Final provisions

14.1 The User can get any clarifications on the questions of interest concerning processing his personal data by contacting the Operator by email at services-elly@ellyanalytics.com.

14.2 This document will reflect any changes in the personal data processing policy of the Operator. The Policy is valid indefinitely until a new version replaces it.

14.3. The current version of the Policy is freely available on the Internet at https://ellyanalytics.com/privacypolicy/.

15. Google data usage

Application Ellyanalytics.com use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.