General provisions and definitions
Alt LLC has appointed Data Protection Officer (DPO). The Response person of the GDPR meets the requirements of the General Data Protection Regulation. 2.
The terms listed below have the meanings assigned to them in the Regulation (EU) 2016/679 (General Data Protection Regulation) and the accompanying Policy: 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; Processing
means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction; Controller
means any 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; where the purposes and means of such processing are determined by European Union or Member State law, the Alt LLC or the specific criteria for its nomination may be provided for by European Union or the law of the Russian Federation. Data subject
is an identified or identifiable natural person who can be identified, directly or indirectly, based on particular information representing personal data; 3.
Alt LLC acknowledges the privacy of natural persons and makes efforts to protect them against any unlawful processing of their personal data. Alt LLC applies the relevant technical and organisational measures to protect the personal data of natural persons in accordance with the effective legislation. Processing of personal data
Alt LLC, in its capacity as Controller of personal data, processes personal data in a manner that ensures appropriate level of security, including protection against unauthorised or illegal processing and against accidental loss, destruction or damage, while applying suitable technical and / or organisational measures in compliance with the following principles:
(a) lawfully, fairly and in a transparent manner in relation to the data subject ("lawfulness, fairness and transparency")
(b) data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes ("appropriateness in the processing of personal data and purpose limitation")
(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed ("data minimisation")
(d) accurate and kept up to date
(e) limitation of the storage for periods not longer than necessary for the purposes for which they are processed ("storage limitation")
(f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures ("integrity and confidentiality"). 5.
Alt LLC processes personal data only if and to the extent at least one of the conditions listed below shall apply:
(a) Processing is required for the performance of an agreement with the Alt LLC under which the data subject is party or to undertake steps at the request of the data subject prior to the signing of an agreement with the Alt LLC.
(b) Processing is required for compliance with a legal obligation which applies to the Alt LLC in its capacity as Alt LLC of personal data.
(c) the data subject has given consent for the processing of their personal data for one or more specific purposes. In the cases when personal data are processed solely on the grounds of consent, the data subject has the right to withdraw such consent at any time. Withdrawal of the consent of the data subject is not applicable in the cases when the processing of the data is based on the provisions of items "a" and "b" above. 6.
Alt LLC, in its capacity as Alt LLC, does not process personal data which reveal racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, and the processing of genetic data, biometric data solely for the purpose of identification of the natural person, data concerning health or data concerning sex life or sex orientation of the natural person unless the data subject have given an explicit consent for the processing of such data for one or more specific purposes. Purpose of personal data processing (how we use your data).
7. Type of purpose General purpose:
- Sales and shipping process
- Ordering an equipment
- Direct marketing
Other Data You Explicitly Submit
- When you pre-ordering or ordering equipment or other services, Alt LLC asks for your name, name of your organization and e-mail address. Providing such information is necessary for further communication with you.
Using the company's website
- We collect and process Personal Data that you send us in clear form (for example, forums, chat rooms, reviews or other materials created by the user). This data includes information:
- that you post, comment or follow in any of our social media;
- sent through chat;
- that you provide when you request information or technical support from us or purchase products, including information necessary to process your orders using the appropriate payment mechanism or for the delivery service;
- You provide to us when participating in competitions, contests and tournaments or responding to surveys, e.g. your contact details.
Tracking data and cookies
- We collect a variety of information through your general interaction with the website.
- Personal Data we collect may include, but is not limited to, browser and device information, data collected through automated electronic interactions and application usage data.
- Likewise, we will track your process across our websites and applications to verify that you are not a bot and to optimize our services.
On behalf of the website operator, Google will use this information for the purpose of evaluating the website for its users, in order to compile reports on website activity, and to provide other services relating to website activity and internet usage for website operators.
Furthermore, users can prevent the collection of data about their use of the website (including their IP address) generated by the cookie, and the processing of data by Google, by downloading and installing the browser plug-in through the following link: http://tools.google.com/dlpage/gaoptout?hl=en
. Yandex Metrica service
The Yandex Metrics service uses the "cookie" technology — small text files placed on the user's computer in order to analyze their user activity.
The information collected by the cookie cannot identify you, but it can help us improve our site. Information about the use of this site by you, collected with the help of a cookie, will be transferred to Yandex and stored on the Yandex server in the EU and the Russian Federation. Yandex will process this information to evaluate the use of your site, compiling reports on the activities of our site, and providing other services. Yandex processes this information in the order established in the conditions of using the Yandex Metrica service.
You can opt out of using cookies by selecting the appropriate settings in the browser.
Also you can use the tool — yandex.ru/support/metrika/general/opt-out.html
. However, this can affect the operation of some functions of the site. By using this site, you agree to the processing of data about you by Yandex in the manner and purposes indicated above. Facebook Tracking Pixel service
You may at any time object to using your information for such remarketing. You can disable Facebook Tracking Pixel in your Facebook account settings or in the following cookie tracking settings at any time. Content recommendation
In accordance with your individual consent or in cases where this is expressly permitted by applicable e-mailing laws, Alt LLC may send you marketing messages on your email address about products and services offered by Alt LLC. In this case, we can also use your collected information to set up such marketing messages, and collect information about whether you opened the message and what link in the text you clicked on).
You can opt out or withdraw your consent to receive marketing emails at any time by either withdrawing the consent clicking the "unsubscribe" link provided in every marketing email. Rights of the data subjects (customers — natural persons whom the data relates to) 8. Right to information
(in relation to the processing of the data subject's personal data by the Alt LLC- the natural persons that are data subjects have the right to receive information* as to the Alt LLC as personal data Alt LLC, as well as the processing of their personal data. 9. Right of access to own personal data
— the data subjects have the right to receive from the Alt LLC confirmation as to whether personal data related to them are processed and if so, to be given access to the data and the following information: purpose of the processing; respective personal data categories; personal data recipients or categories of recipients, if any; the intention of the Alt LLC to transmit personal data to a third party (where applicable); personal data storage period; existence of the right to correct personal data, as well as the right to object against the processing of personal data; existence of automated decision making, including profiling (if any); information as to all rights that the data subject has; the right to file a complaint with the supervision authority. 10. Right to rectification of personal data
(if data is not accurate) — the data subject has the right to request the Alt LLC to rectify, without undue delay, any incorrect data pertaining to the data subject. 11. Right to erasure of personal data
(right "to be forgotten") — the data subject may request from the Alt LLC to erase personal data, if any of the conditions listed below exist:
12. Right to limitation of processing
- Personal data are no longer needed for the purposes they have been collected for or processed otherwise;
- The data subject withdraws his / her consent, which data processing is solely based on, and no other legal grounds for the processing exist (processing due to regulatory obligation of the Alt LLC, an agreement signed with the Alt LLC);
- The data subject objects against the processing and no legal grounds for the processing exist that prevail;
- The personal data were processed unlawfully;
- The personal data should be erased in order to comply with a legal obligation under the European Union law or the laws of the Russian Federation, which apply to the Alt LLC in its capacity as personal data Alt LLC;
- The personal data have been collected in relation to the offering of information society services to children and consent was given by the holder of parental responsibilities for the child.
by the Alt LLC or by the personal data processor — specific conditions are required to be in place for that right to be exercised, namely:
13. Right to transferability (data portability)
- Accuracy / up to date nature of the data is disputed by the data subject. In this case the limitation of the processing is over a period of time allowing the Alt LLC to check the accuracy of the personal data;
- The processing is unlawful, but the data subjects do not wish their personal data to be erased, but rather require limitation of their use;
- The Alt LLC no longer needs such personal data for processing purposes, but the data subject requires them for establishing, exercising or defending legal claims;
- The data subject has objected to the processing while awaiting a check to be performed whether the Alt LLC's legal grounds prevail over the interests of the data subject.
of the personal data between the various Alt LLCs — the data subjects have the right to receive personal data pertaining to them, which they have provided to the Alt LLC in a structured, widely used and machine readable format and have the right to transfer such data to another Alt LLC without hindrance by the Alt LLC, to which personal data has been provided, when processing is based on consent or contractual obligation and the processing is automated. When exercising the right to transferability the data subject has the right to receive also direct transfer of the personal data from the Alt LLC to another Alt LLC, where technically feasible. 14. Right to object
against the processing of their personal data — data subjects have the right to object before the Alt LLC against the processing of their personal data, whereby the Alt LLC shall cease such processing, unless Alt LLC is able to prove that compelling legitimate grounds for the processing exist that override the interests, rights and freedoms of the data subject, or for the establishment, exercising or defence of legal claims. In case of objection against the processing of personal data for direct marketing purposes the Alt LLC shall cease such processing forthwith. 15.
The data subject also has the right not to be subject to decision based solely on automated processing
, including profiling, which ensues legal consequences for the data subject or significantly affects the data subject otherwise. 16. Right to defence through judicial or administrative procedure
if the data subject's rights have been breached — if the data subjects decide that their right to personal data protection and privacy has been violated, they may file a complaint with the relevant supervision authority — or to file a claim with the court to defend their rights.Disclosure of personal data
Alt LLC may disclose the personal data to the following categories of persons:
Exercise the rights 18.
- The persons whom the data relate to, namely: persons using Alt LLC services or products, or persons filing a request to use Alt LLC services, as well as persons who are party to Alt LLC and / or other transactions and contractual relations with the Alt LLC;
- Persons that have right to access to personal data by virtue of law or another regulation;
- Persons as to whom the right to disclosure is stipulated in an agreement signed with the Alt LLC.
(1) In exercising their right to access natural persons have the right to request from Alt LLC at any time:
1. Confirmation as to whether data related to them are processed by the Alt LLC, the purpose of the processing, the data category and recipients of such data or the categories of recipients' data is disclosed to;
2. To send them a message in an understandable format, containing the personal data subject to processing and any information available as to the source of such data;
3. Information as to the logic of any automated processing of personal data pertaining to natural persons, at least in the case of automated decisions under the provisions of the General Data Protection Regulation
(2) Upon request Alt LLC provides the information under paragraph 1 free of charge.
(3) Natural persons have the right to request at any time that Alt LLC:
1. erases, rectifies or blocks their personal data the processing of which is not compliant with the requirements of the effective legislation
2. notifies the third parties to which the personal data of the natural persons have been disclosed as to any erasure, rectification or blocking in accordance with item 1 above, except when this proves to be impossible or would involve a disproportionate effort. 19. (1)
Natural persons exercise their rights by filing a written request to the Alt LLC, containing as a minimum the following information:
- name, personal ID number, address and other data allowing identification of the respective natural person;
- description of the request;
- Signature, date, correspondence address and telephone number.
(2) The filing of the request is free of charge.
(3) Upon filing of a request by an authorised person, the notarised power of attorney must be attached to the request.
(4) In case of death of the natural person, his / her rights are exercised by his / her heirs and certificate of heirs shall be attached to the request. 20.
The Alt LLC shall review and pronounce on the request within 1 month as of its filing. This period may be extended by further two months, if necessary. The Alt LLC informs the data subject as to any such extension within 1 month as of receipt of the request, stating the reasons for the delay. When the data subject files a request by electronic means, the information is provided electronically, if possible, unless the data subject has requested otherwise. 21.
The Alt LLC provides an answer to the requesting person taking into account their preferred form for the provision of the information (orally or in writing — as a hard copy of electronically). 22.
Where data do not exist or their provision is forbidden by law, access of the requesting party to such data is refused. 23 .
If the requesting party is not satisfied with the response received and / or believes that their rights related to personal data protection were violated, they are entitled to exercise their right to defence.
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Russian Federation Manager:
Desyatov Andrey E-mail: firstname.lastname@example.org Internet site: www.antilatency.com Contact details with Data Protection Officer / EU Representative: Name:
Dimitar Kolchakov E-mail: email@example.com