Privacy Policy

PRIVACY POLICY

Effective date: 2019-03-01

This Policy is an official document of the OMV LLC (official state registration number 1177847332288, registered office 121205, Russian Federation, Moscow, Skolkovo Innovation Center ter, Bolshoy blvd, № 42, building 1, Floor 0 P 27 Pom 263) (hereinafter referred to as the “Varwin” or “We”), and outlines the procedure for the processing and protection of the personal data of individuals using Varwin platform and https://varwin.com website.

Personal data means any information which relates to a living, identifiable person. It can include names, addresses, telephone numbers, email addresses etc but it is wider than that and includes any other information relating to that person or a combination of information which, if put together, means that the person can be identified.

Processing covers all activities relating to the use of personal data by an organisation, from its collection through to its storage and disposal and everything in between.

The purpose of this Policy is to ensure the sufficient protection of your personal data against unauthorized access and disclosure.

The current version of the Policy constitutes a public document and is available to any internet user at  https://varwin.com

This Policy may be amended by the Varwin at its own discretion, and come into effect on the day following the day of publication of such amendments. You`re obliged to independently familiarize yourself with any amendments made to this Policy. 

Actual use of the Varwin platform and https://varwin.com website  after the amendment of the terms of this Policy constitute your acceptance of the new terms.

You can contact Varwins`  authorized person for the protection of personal data, sending a letter to the email address: [email protected]

OUR PRINCIPLES 

Varwin complies with the principles of GDPR, which are:

  1. Lawfulness, transparency and fairness;
  2. Purpose Limitation;
  3. Data Minimization;
  4. Accuracy;
  5. Storage limitation;
  6. Confidentiality and integrity.

WHAT INFORMATION DO WE COLLECT?

To get the access to Varwin platform, you need to register on our https://varwin.com website. During registration, we ask you to provide the following information: 

First name, Last name, E-mail, Phone, Location.

In addition to the information provided directly by you, we also collect:

Information obtained by accessing the site, including information regarding technical equipment (devices), technological interaction with the  site (including host IP address, user’s operating system, browser, geographical location, ISP, information obtained from accessing the camera, microphone, and other devices);

Information obtained automatically by accessing the cookies.

WHAT “COOKIES” DO WE USE?

We collect information by placing cookies on a computer (or computer device). Cookies is a piece of text stored on your device by your web browser. Cookies stores information about visiting a website, recognizes you and your preferences every time you visit our website, and provides the functionality of the website, allowing us to provide services to our users upon request. 

We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our site. 

You may set your browser and your device settings to block cookies and local storage devices, but if you do so, you may not be able to access some of the features that website offers. 

We will notify you of any important changes to our use of cookies and local storage devices.

FOR WHAT PURPOSES DOES VARWIN USES PERSONAL DATA?

We use your personal data for purposes of:

  1. Verifying your identity (for example when you return to the website and have already logged in);
  2. Improving the design, style and useability of the website; 
  3. Detection, prevention and addressing technical issues;
  4. Sending you service messages;
  5. Generation of aggregated statistics about the users of our products and services;
  6. Assisting in security and cyber-crime prevention;
  7. Providing you with information  about our products, services and events that may be of interest to you by letter, telephone, email or other forms of electronic communication.

Should we need to process your data for any other purpose in accordance with the provisions set out in this Privacy Policy, we will provide you with detailed information about this additional purpose before we begin processing.

 

The legal ground for processing personal data according to the above-listed purposes is your consent.

You may withdraw your consent at any time. You will not suffer any detriment for withdrawing your consent. If you withdraw your consent, this will not make processing which we undertook before you withdrew your consent unlawful. You can withdraw your consent by sending a letter to the email address: [email protected]

HOW LONG PERSONAL DATA WILL BE STORED?

Your personal data will not be kept for longer than is necessary to fulfil the specific purposes outlined in this Privacy Policy and allow us to comply with our legal requirements. Any data we do hold onto will be anonymous. Any personally identifiable information such as your First name, Last name, E-mail and Phone number will be deleted after a defined period or within 30 days from moment of receiving your request to delete it.

The rest of the data is therefore anonymous and will be used to analyse general market and website trends but without an identifiable personal information.

WHERE IS PERSONAL DATA STORED?

We use a network of servers including outside the European Union. This hardware is located in third-party data centers, but belongs to Varwin. We guarantee that the data will be adequately protected and that existing legal schemes such as those approved by the EU and the countries hosting the software and hardware for confidentiality will be respected, and reliable contractual standards will be implemented. If you want more information about our security measures, please write to us at [email protected]

HOW DOES VARWIN  PROTECT PERSONAL DATA?

Varwin takes the necessary technical and organisational security measures to protect and prevent loss, misuse and alteration of information under our control, including your personal data. Our technical specialists are constantly working to ensure that our site  remains safe and secure.

We restrict access to personal information to Varwin employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

 

If you have a personal password which enables you to access certain parts of our website, do not forget your responsibility for keeping this password confidential. We ask you not to share your password with anyone.

WITH WHOM VARWIN SHARES PERSONAL DATA?

We share personal data with the following categories of third parties:

  1. IT companies (hardware and software) that provide capacity and other services to support our products;
  2. Fraud prevention and anti-spam services to protect the service from criminal activity;
  3. Law enforcement agencies, if necessary, provide data on the law, as well as to protect life;
  4. Payment and telecommunication companies for payment of our services.

We guarantee that these parties act in accordance with the data protection and confidentiality provisions of this Policy. We do our best to ensure that all data remains as anonymous. 

In the event that Varwin  or any of our partners who own your data legally transfers business or changes ownership, for example, due to the takeover by another company or the merger, reorganization or sale of all or part of the assets, as well as in case of insolvency, we can be required to disclose your personal information.

YOUR RIGHTS

You have a number of rights under European Data Protection legislation if you are in EU, more specifically:

  1. Right to be informed: what personal data an organisation is processing and why;
  2. Right of access: you can request a copy of your data;
  3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected;
  4. Right to erasure: you have the right to have your data deleted in certain circumstances;
  5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained;
  6. Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider;
  7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing;
  8. Rights related to automated decision making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

If you want to exercise any of your rights listed above (as well as any other rights provided by applicable legislation) please email us at [email protected]

AGE

By completing a registration you confirm that you are of the legal age of majority in the country, state or province of your residence (which, for purposes of this Policy, is 16 for citizens of EU and 18 for citizens of other countries).

If we become aware of the registration of a user under the age of majority  and the provision of their personal data, we will take measures to remove such profile and any information about it from our site.

If we deleted your profile because you violated our minimum age rule, we can save your email and IP addresses so you do not try to bypass our rules by creating a new profile.

COMPLAINTS

If you have any complaints about how we handle your personal data, please contact us via e-mail [email protected] so we can resolve the issue, where possible. You also have the right to lodge a complaint about any use of your information with the data protection regulator (supervisory authority).