Personal Data Processing Policy

1. General provisions.

This Personal Data Processing Policy has been drawn up in accordance with the requirements of the Federal Law No. 152-FZ dated 27.07.2006 «On Personal Data» and determines the order of personal data processing and measures to ensure the security of personal data taken by ReckonGrupp LLC (hereinafter — the «Operator»).

1.1. The Operator’s most important goal and condition for its activities are to observe human and civil rights and freedoms when processing personal data, including the protection of rights to privacy, personal and family secrets.

1.2. This Operator’s policy regarding the processing of personal data (hereinafter — the «Policy») applies to all information that the Operator may receive about visitors to the website  https://reckongroupit.com/.

2. Basic concepts used in the Policy.

2.1. Automated processing of personal data — processing of personal data by means of computer technology;

2.2. Personal data blocking means temporary termination of personal data processing (except when processing is necessary to clarify personal data);

2.3. Website means a set of graphic and informational materials, as well as computer programs and databases, making them available on the Internet at the network address https://reckongroupit.com/;

2.4. Information system of personal data means a set of personal data contained in databases of personal data, and information technology and technical means that ensure their processing;

2.5. Anonymization of personal data means actions that make it impossible to determine, without the use of additional information, what personal data belongs to a particular user or other personal data subject;

2.6. Personal data processing means 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;

2.7. Operator means a state authority, municipal authority, legal entity or individual, independently or together with other persons, organizing and (or) performing the personal data processing, 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 means any information relating directly or indirectly to an identified or identifiable User of the website https://reckongroupit.com/;

2.9. User means any visitor to the website https://reckongroupit.com/;

2.10. Provision of personal data means actions aimed at disclosure of personal data to a certain person or a certain circle of persons;

2.11. Dissemination of personal data means any action aimed at the disclosure of personal data to an indefinite range of persons (transfer of personal data) or to familiarize with personal data to an unlimited number of persons, including the publication of personal data in the media, placing in information and telecommunications networks or providing access to personal data in any other way;

2.12. Cross-border transfer of personal data means a transfer of personal data to the territory of a foreign country to a foreign authority, a foreign individual or a foreign legal entity;

2.13. Destruction of personal data means any action resulting in the destruction of personal data irretrievably with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) the destruction of the material media of personal data.

3. The operator may process the following personal data of the User.

3.1. Last name, first name, patronymic;

3.2. E-mail;

3.3. Phone numbers;

3.4. The website also collects and processes impersonal data about visitors (including cookies) using Internet statistical services (Yandex Metrika and Google Analytics and others).

3.5. The above-mentioned data, hereinafter referred to as «Policies», are grouped under the general term «Personal Data».

4. Purposes of personal data processing.

4.1. The purpose of the processing of the User’s personal data is to inform the User by sending emails; conclusion, execution and termination of civil law contracts.

4.2. The Operator shall also have the right to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive information messages by sending an email to the Operator at support@reckongruppit.com with a note «Refusal of notifications about new products and services and special offers».

4.3. Anonymized data of Users collected through Internet statistical services are used to collect information about Users’ actions on the website, to improve the quality of the website and its content.

5. Legal basis for personal data processing.

5.1. The Operator processes the User’s personal data only if the User fills them out and/or sends them by itself through the special forms located on the website https://reckongroupit.com/. By filling in the appropriate forms and/or sending its personal data to the Operator, the User expresses its consent to this Policy.

5.2. The Operator processes anonymized data about the User if it is allowed in the settings of the User’s browser (cookie saving and the use of JavaScript technology are enabled).

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

The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to comply fully with the requirements of applicable laws in the field of personal data protection.

6.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

6.2. The User’s personal data will never, under any circumstances, be disclosed to third parties, except in cases related to the execution of applicable law.

6.3. In case of detection of inaccuracies in the personal data, the User can update them independently, by sending a notice to the Operator’s e-mail address support@reckongrupp.com with a note «Updating of personal data».

6.4. The term of personal data processing is unlimited. The User may withdraw their consent to the processing of personal data at any time by sending a notice by e-mail to the Operator’s e-mail address support@reckongruppit.com marked «Withdrawal of consent to the processing of personal data».

7. Cross-border transfer of personal data

7.1. Prior to the cross-border transfer of personal data, the Operator must ensure that the foreign country to whose territory the transfer of personal data is to be carried out, provides reliable protection of the rights of personal data subjects.

7.2. Cross-border transfer of personal data in foreign countries that do not meet the above requirements may be carried out only if the consent in writing of the personal data subject to the cross-border transfer of its personal data and/or performance of the contract, to which the personal data subject is a party.

8. Final provisions.

8.1. The User can get any clarifications on questions of interest concerning the processing of its personal data by contacting the Operator via e-mail support@reckongruppit.com.

8.2. 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.

8.3. An up-to-date version of the Policy is freely available on the Internet at https://reckongroupit.com/privacy.