- why we are able to process your information;
- what purpose we are processing it for;
- whether you have to provide it to us;
- how long we store it for;
- whether there are other recipients of your personal information;
- whether we intend to transfer it to another country.
Definitions and Interpretation
“Consent” means agreement, which must be freely given, specific, informed and be an unambiguous indication of the Data Subject's wishes by which they, by a statement or by a clear positive action, signify agreement to the Processing of Personal Data relating to them.
“Data controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;
“Data processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
“Data subject”, “You”, “your” or “data subject” means:
- Visitors to our websites;
- Prospective or existing customers and partners;
- Job applicants.
“Personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. The definition incorporates, where applicable, the definitions provided in the General Data Protection Regulation (EU 2016/679).
“Processing” means any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.
Who We Are (Identity Of The Data Controller)
For the purpose of the General Data Protection Regulation the data controller (“we”, “us” and “our”) is “1C INTERNATIONAL” LLC and its data processors.
Data Protection Officer's contact details
Our Data Protection Officer is Elena Riazanova. You can contact her at email@example.com.
Personal data we may collect from you
Most of the personal information we process is provided to us directly by you for the following reasons:
We collect the information provided by you to operate effectively and provide you the best experiences with our websites, products and services.
You provide some of this information by filling in the contact forms on our websites, creating an account at our websites, corresponding with us by phone, e-mail or otherwise, subscribing to any service we offer through our site, sending us a query or feedback, signing up for information on events, uploading a document with your enquiry, purchasing services via our websites, participate in discussion boards or other social media functions on our websites, participating in a promotion or a survey, reporting a problem.
The information you may provide us is Personally Identifiable Information that identifies an individual or may with reasonable efforts cause the identification of an individual, and may include the following data:
First name, surname, e-mail address, phone number, job title, country and city of the place of business, business address.
If you are our registered partner, in order to participate in our live partner events and make the required reservations we might ask you to provide us a copy of your identification document.
We do not sell any products or services for purchase by children. If you are under 16, you may use our websites only with the involvement of your holder of parental responsibility. We do not knowingly collect personal information from children below 16 without the consent of the child’s holder of parental responsibility.
Information You Provide About Others
In providing personal data about other individuals (such as someone in whose name you are registering an account or subscribing to our marketing promotions), you represent that you have notified them of (i) the purposes for which information will be used (ii) the recipients of their personal data and (iii) how they can access and correct the information. You further represent that you have obtained all necessary consents from them.
This technical information might have included:
Device and connectivity information such as IP (Internet Protocol) address, browser type and version, language settings, time zone settings, browser plug-in types and versions, pages you viewed or searched for, full uniform resource locators (URL), methods used to browse away from the page, clickstream to, through and from the site (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), log information, such as error reports, download errors, any problems experienced while accessing our websites.
We do not match information collected automatically through cookies and analytics tools with other personally identifiable information you may have provided to us when you created an account or submitted a form or contacted us in any other way.
Social media plugins
Our Website might include certain Social Media plugins, such as:
These Social Media plugins may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Please be aware that if you choose to interact or share any Personal Information via such plugins, you are in fact providing it to these third parties and not to us. Your interactions with these third parties are managed by these Social Media privacy policies and not ours. For example, you will not be able to use the “Facebook Follow” button if you are not logged in to your Facebook account. Once you use the button this will be associated with your Facebook history, but we will not process this information. We encourage you to read the privacy notices of the plugins you use.
Where we provide links to websites of other organizations, this privacy notice does not cover how that organization processes personal information. We encourage you to read the privacy notices on the other websites you visit.
Trusted Partners (Data Processors) who Work On Our Behalf Under Confidentiality Agreements And Might Store, Maintain Or Process Your Data:
We have partnered with a number of authorized service providers (data processors), whose services and solutions complement, facilitate and enhance our own under written confidentiality agreements that guarantees that the requirements of the GDPR will be met and the rights of data subjects are protected. Data processors only act on behalf of our documented instructions. They have direct responsibilities under the GDPR and may be subject to fines or other sanctions if they don’t comply.
These might include:
Hosting and landing website service providers, e-mail distribution and monitoring services, video conferencing services, services for building integrations, customer services management software; Such data processors may receive or otherwise have access to your identifiable or non-identifiable personal data, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes. Under no circumstances may data processors will use the data for their own purposes.
Once this contract is concluded, data processor will return data to us or transmit to another processor appointed by us, and erase any copy in its possession. However, the processor may keep the data locked to address possible administrative or jurisdictional responsibilities.
We will keep your personal data during the performance of an oral or written contract between you and us or during the communication process related to the steps prior to entering a prospective verbal or written contract.
We may continue to retain such Personal Information even after the contract between parties terminates, as reasonably necessary to comply with our legal obligations or to protect our legitimate interests if applicable. We will use reasonable endeavors to ensure your data is up-to-date. As a data subject you have rights related to maintenance, storage and processing of your personal data. Please see paragraph “Your rights”.
Unless otherwise specified, where you have indicated to us that you are happy for us to send you the information about our products and services we offer and we feel may interest you or similar to those that you have already purchased or enquired about do so, we assume you are happy for us to keep your collected personal data. We may retain your Personal Information (contact details) for as long as your User Account is active or as otherwise needed to provide you with information about our services. As the data subject you have rights related to processing of your personal data and the option of withdrawing your consent to receive promotions at any time. Please see paragraph “Your rights”.
How we will use your personal data (Lawful basis for processing)
1. To take steps at the request of the data subject prior to entering into a business relationship (oral or written contract):
1.1 By contacting us by means specified in paragraph “Personal Data we may collect from you”, we assume that processing is necessary for the performance of a business relationship (oral or written contract) or in order to take steps prior to entering into a business relationship (oral or written contract), and therefore the lawful basis is Contract.
1.2 We will use the provided information to do our best to respond to your enquiries.
1.3 Once you enter into a business relationship (oral or written contract) with us, we will invoice our services.
1.4 We might use your unique device fingerprints for license administration purposes, application of new licenses, convert evaluation licenses to permanent licenses, and perform other license-related maintenance.
1.5 We will use your contact details to provide you training on our products and services.
2. Based on our legitimate interests: 2.1 To promote our products and services online. 2.2 To collect information about how visitors use our website. 2.3 Website improvement.
We might use your automatically collected data such as IP address and browser data for our Website improvement, such as:
2.3.1 To administer our site and for internal operations, including data security, troubleshooting, testing, statistical and survey purposes; 2.3.2 To ensure that content from our site is presented in the most effective manner for you and for your device.
3. Based on your Consent:
3.1 To send you communications, including promotional communications and advertising with your explicit consent or allow you to participate in interactive features of our service, when you choose to do so.
3.2 If you wish not to receive such promotional e-mails, you may withdraw your consent at any time by contacting us as described in paragraph “Your rights” or follow the “unsubscribe” or instructions contained in the promotional communications you receive.
4. Based on our Legal obligation:
We might hold your information for as long as is necessary to comply with our and legal obligations and in accordance with our legitimate interests as a data controller after the contractual relationship between you and us elapses. The lawful basis for such retention is legitimate interests and Legal obligation. As the data subject you have rights related to maintenance, storage and processing of your personal data. Please see paragraph “Your rights”.
- All “1C INTERNATIONAL” LLC IT Systems are protected against unauthorized access and used only in compliance with the relevant Company Policies;
- All “1C INTERNATIONAL” LLC employees and any third parties authorized to use the IT Systems must ensure that they are familiar with this Policies and must adhere to and comply with it at all times.
All data stored on IT Systems are managed securely in compliance with all relevant parts of EU Regulation 2016/679 General Data Protection Regulation (“GDPR”) and all other laws governing data protection whether now or in the future in force and protected against loss and corruption;
- All software in use on the IT Systems (including, but not limited to, operating systems, individual software applications, and firmware) are kept up-to-date and any and all relevant software updates, patches, fixes, and other intermediate releases are applied;
- All confidential data is stored encrypted.
Disclosure of information to third parties
We do not rent, sell, or share personal information about you with other people or non-affiliated companies without your consent except to provide products or services you’ve requested, when we have your permission, or under the following circumstances:
- We provide the information to trusted partners who provide us services under confidentiality agreements, specified in Paragraph “Trusted Partners (Data Processors) who Work On Our Behalf Under Confidentiality Agreements And Might Store, Maintain Or Process Your Data:” These companies do not have any independent right to share this information.
- We may disclose your information to third parties when we reasonably believe we are obligated to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person. We may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you. Your details may also be disclosed to the police and law enforcement agencies for the purpose of fraud detection, crime prevention and national security.
Choices available to you
You can always choose whether or not to disclose personally identifiable information and that choice will not prevent you from using the Website. Please note, however, if you should choose to withhold requested information, we may not be able to provide you with some of the services offered through this website.
If you are a California resident: We will not share any Personal Data with third-parties for their direct marketing purposes to the extent prohibited by California law. If our practices change, we will do so in accordance with applicable laws and will notify you in advance.
In European Union and some other jurisdictions, you may have the following rights concerning our processing of your personal data:
- THE RIGHT TO ACCESS INFORMATION HELD ABOUT YOU. You have the right to ask us for copies of your personal information. This right always applies.
- THE RIGHT TO RECTIFY YOUR PERSONAL DATA if it is inaccurate, incomplete or out-of-date. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.
- THE RIGHT TO ERASURE (DELETE OR REMOVE) YOUR PERSONAL DATA. You have the right to ask us to erase your personal information in certain circumstances.
- THE RIGHT TO RESTRICT (BLOCK) PROCESSING. When processing is restricted, we will store your personal data, but not further process it. You have the right to ask us to restrict the processing of your information in certain circumstances.
- THE RIGHT TO DATA PORTABILITY is your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and the right to transmit that data to another controller from the current controller applicable if: The processing is based on consent or on a contract, and the processing is carried out by automated means.
- RIGHTS RELATED TO AUTOMATED DECISION MAKING INCLUDING PROFILING. We are not making any profiling with legal or similar effects.
- THE RIGHT TO WITHDRAW YOUR CONSENT OR OBJECT TO DIRECT MARKETING AND OTHER TYPES OF PROCESSING IF APPLICABLE.
- You have the right to lodge a complaint with a supervisory authority if you have a concern about our information rights practices.
You can exercise your rights by contacting our Data Protection Officer at firstname.lastname@example.org.