Policy on Personal Data Processing
1. General ProvisionsThis policy on personal data processing is compiled in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" dated 27.07.2006 (hereinafter referred to as the "Personal Data Law") and the General Data Protection Regulation 2016/679 of the European Parliament and Council of the European Union dated April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as "GDPR") and determines the procedure for processing personal data and measures to ensure the security of personal data, implemented by the Administration of the website
https://native-call.com/ (hereinafter referred to as the "Operator").
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including protecting the right to privacy, personal and family secrets, as its most important goal and condition for carrying out its activities.
1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website
https://native-call.com/.
1.3. The Operator provides its services exclusively to individuals who are at least 18 years old and capable of acquiring civil rights for themselves and exercising them independently through their actions.
1.4. Furthermore, the Operator holds two legal statuses simultaneously, as provided by the Data Protection Rules: (a) Data Controller (b) Data Processor
1.5. Users who intend to use the website's functionality for the first time, including in test format, must familiarize themselves with the provisions of this Privacy Policy in advance.
1.6. Users using the website's functionality at the time the Privacy Policy takes effect must familiarize themselves with its current provisions. The Operator is not obligated to send out the current version of the Privacy Policy to the individuals mentioned in this section.
1.7. Users who have read the provisions of this Privacy Policy express their full agreement with the terms of this Privacy Policy and grant the Operator the right to use and process their personal data for the purposes provided by the website's functionality.
1.8. If you disagree with the provisions of this document (in whole or in part), you are not entitled to use the website.
2. Basic Terms Used in the Policy2.1. Automated processing of personal data: Processing of personal data using computing technology.
2.2. Blocking of personal data: Temporary suspension of personal data processing (unless processing is necessary for clarifying personal data).
2.3. Website: A set of graphical and informational materials, as well as software and databases, making them available on the internet at the network address
https://native-call.com/.
2.4. Information system of personal data: A set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Depersonalization of personal data: Actions resulting in it being impossible to determine the identity of personal data belonging to a specific user or other subject of personal data without additional information.
2.6. Personal data processing: Any action (operation) or a set of actions (operations) performed using automation tools or without such tools concerning personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator: A state body, municipal body, legal or physical person that organizes and/or carries out the processing of personal data, individually or together with other entities, and determines the goals 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 defined or identifiable user of the website
https://native-call.com/. This includes information such as name, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity, including but not limited to IP addresses, name, email address, contact phone number, API tokens, payment information, HTTP response code.
2.9. Personal data allowed by the personal data subject for dissemination: Personal data which access is provided to an unlimited range of persons by the personal data subject giving consent for the processing of personal data allowed by the personal data subject for dissemination in the manner prescribed by the Personal Data Law (hereinafter referred to as "personal data allowed for dissemination").
2.10. User: Any visitor to the website
https://native-call.com/.
2.11. Provision of personal data: Actions aimed at disclosing personal data to a specific person or a specific range of persons.
2.12. Dissemination of personal data: Any actions aimed at disclosing personal data to an indefinite range of persons (transfer of personal data) or at familiarizing with personal data an unlimited range of persons, including the publication of personal data in the media, placement in information and telecommunication 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, foreign state authority, foreign legal or foreign physical person.
2.14. Destruction of personal data: Any actions resulting in the personal data being irrevocably destroyed with the impossibility of further restoring the content of personal data in the personal data information system and/or the physical media of personal data being destroyed.
2.15. General Data Protection Regulation ("GDPR"): General Data Protection Regulation 2016/679 of the European Parliament and Council of the European Union dated April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
3. Main Rights and Obligations of the Operator3.1. The Operator has the right to: — Receive accurate information and/or documents containing personal data from the personal data subject; — Continue processing personal data without the consent of the personal data subject if the personal data subject withdraws consent to personal data processing or sends a demand to stop processing personal data, provided there are grounds specified in the Personal Data Law; — Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations provided by the Personal Data Law and regulatory legal acts adopted in accordance with it unless otherwise provided by the Personal Data Law or other federal laws. — Use the information provided by the User, including personal data, to ensure compliance with the requirements of Russian Federation laws and the laws of the User's place of residence (including to prevent and/or suppress illegal and/or unlawful actions of Users). Disclosure of the information provided by the User can only be made in accordance with the legislation of the Russian Federation and the laws of the User's place of residence at the request of the court, inquiries of law-enforcement authorities, and other cases provided by the law of the applicable jurisdiction.
3.2. The Operator is obligated to: — Provide the subject of personal data upon their request with information regarding the processing of their personal data; — Organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation; — Respond to requests and inquiries from personal data subjects and their legal representatives following the requirements of the Personal Data Law; — Notify the authorized body for the rights protection of personal data subjects of necessary data within 10 days from the request's date; — Publish or otherwise provide unrestricted access to this personal data processing policy; — Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions with regard to personal data; — Cease the transfer (dissemination, provision, access) of personal data, terminate processing, and destroy personal data in the manner and in cases provided by the Personal Data Law; — Fulfill other obligations provided by the Personal Data Law.
4. Basic Rights and Obligations of Subjects of Personal Data4.1. Subjects of personal data have the right to: — Receive information regarding the processing of their personal data, except in cases stipulated by federal laws. The information should be provided by the Operator to the personal data subject in an accessible form and should not contain personal data related to other personal data subjects unless there are legal grounds for disclosing such personal data. The list of information and the procedure for its receipt are established by the Personal Data Law; — Demand the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the declared purpose of processing, and take measures prescribed by law to protect their rights; — Set a condition for preliminary consent during the processing of personal data for the promotion of goods, works, and services on the market; — Withdraw consent to personal data processing and demand the cessation of personal data processing; — Exercise other rights provided by the legislation of the Russian Federation. — Concerning the processing purposes by the Operator; — Entities to whom the personal data was or will be disclosed, particularly recipients in countries outside the European Union or international organizations; — The planned period during which personal data will be stored, or if not possible, the criteria used to determine this period; — Receive from the Operator deletion of personal data without undue delay if there is at least one of the following grounds: a) Personal data is no longer needed for the purposes it was collected or processed for; b) The User disagrees with the provisions of the Privacy Policy; c) There are no overriding legitimate grounds for processing; d) The personal data was unlawfully collected and/or processed.
4.2. If the Operator allows a situation in which the User's data becomes publicly available, the Operator must delete such User data and take reasonable steps, including technical measures, to inform individuals processing such personal data of the User's desire to delete any links to this data or prevent its copying or replication.
4.3. Subjects of personal data must: — Provide the Operator with accurate data about themselves; indicate accurate information about themselves as necessary for using the website's services. Mandatory fields for service provision marked with an asterisk "*", all other information provided at the User's discretion. — Notify the Operator about clarifying (updating, changing) their personal data.
4.4. Individuals who have provided the Operator with false information about themselves, or information about another subject of personal data without the latter's consent, bear responsibility following the legislation of the Russian Federation.
5. Principles of Personal Data Processing5.1. Personal data processing must be carried out on a lawful and equitable basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and legitimate goals. Processing personal data incompatible with the collection's purposes is not allowed.
5.3. Combining databases containing personal data processed for incompatible purposes is not allowed.
5.4. Only personal data meeting the processing objectives is subject to processing.
5.5. The content and volume of processed personal data must correspond to the declared processing purposes. Excessive personal data relative to the stated processing purposes is not allowed.
5.6. Personal data accuracy, its sufficiency, and, where necessary, its relevance concerning the processing purposes must be ensured during the processing. The Operator must take or ensure the necessary measures to delete or clarify inaccurate or incomplete data.
5.7. Personal data storage must be in a form allowing the identification of the personal data subject no longer than required for personal data processing purposes unless the storage period is established by federal law, agreement, where the personal data subject is a party, beneficiary, or guarantor. Processed personal data must be destroyed or anonymized upon achieving the processing purposes or loss of the necessity to achieve these purposes unless otherwise provided by federal law.
6. Personal Data Processing PurposesPurpose of Processing Providing User access to services, information, and/or materials contained on the website.
Personal Data — Last name, first name, middle name — Email address — Phone numbers — Year, month, date, and place of birth — Photographs — First name, last name — Name — Country of account registration address
Types of Personal Data Processing — Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data — Sending information letters to the email address — Sending messages to the phone number/messenger
7. Conditions for Personal Data Processing7.1. Personal data processing is carried out with the consent of the personal data subject to process their personal data.
7.2. The processing of personal data is necessary for achieving purposes stipulated by an international treaty of the Russian Federation or law, for performing functions, powers, and responsibilities imposed on the Operator by Russian legislation.
7.3. The processing of personal data is necessary for administering justice, executing a judicial act, an act of another body or official, enforced in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for executing an agreement to which the data subject is a party, beneficiary, or guarantor, as well as for concluding an agreement at the data subject's initiative or an agreement under which the data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for exercising rights and legitimate interests of the Operator or third parties or achieving significant public goals, provided it doesn't violate the rights and freedoms of the personal data subject.
7.6. The Operator provides access to the personal data of the User only to persons necessary to ensure the website's functionality and service provision to the User.
7.7. The processing of personal data subject to publication or mandatory disclosure under federal law is carried out.
7.8. The Operator takes all necessary measures to protect the User's personal data from unauthorized access, alteration, disclosure, or destruction.
7.9. Despite all commercially reasonable measures taken by the Operator to prevent unauthorized third-party collection of Users' personal information transmitted to the Operator through the website, illegal interception or acquisition of information by third parties remains possible.
7.10. In case of a data breach/hack/compromise of personal data, the Operator must notify relevant authorities no later than 72 hours after becoming aware of such breach/hack/compromise.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data ProcessingThe security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with current legislation in the field of personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. The User’s personal data will not be transferred to third parties under any circumstances, except as required by applicable law or if the personal data subject has given consent to the Operator to disseminate personal data and/or transfer data to a third party to fulfill obligations under a civil-law contract.
8.3. If inaccuracies in personal data are detected, the User can update them independently by sending the Operator a notification to the Operator's email with the marked "Personal Data Update".
8.4. The personal data processing period is determined by achieving the purposes for which the personal data was collected unless another period is provided by an agreement or current legislation. The User can withdraw their consent to process personal data at any time by sending the Operator a notification via email marked "Withdrawal of Consent to Personal Data Processing".
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by these parties (Operators) following their User Agreement and Privacy Policy. The personal data subject and/or with the specified documents. The Operator is not responsible for the actions of third parties, including those mentioned in this section.
8.6. The personal data subject's prohibitions on transferring (except granting access) the personal data allowed for dissemination, processing or conditions of processing (except obtaining access), do not apply in cases of processing personal data in state, public, and other public interests defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows the identification of the personal data subject, no longer than necessary for the purposes of personal data processing unless a more extended period is required by federal law, agreement, in which the personal data subject is a party, beneficiary, or guarantor.
8.9. The processing of personal data may be terminated upon achieving the personal data processing purposes, the expiry of the consent period for personal data processing, the personal data subject's withdrawal of consent, or the requirement to cease the processing of personal data, as well as revealing unlawful processing of personal data.
9. List of Actions Performed by the Operator with Received Personal Data9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (update, change), retrieval, usage, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated personal data processing, including receiving and/or transmitting obtained information via information and telecommunication networks or without it.
10. Under this Privacy Policy, "personal information about the User" means:10.1. Data provided by the User independently during the website usage process, including but not limited to: name, surname, contact phone number, email address, photo, IP address, MAC address, and more.
10.2. Data automatically transmitted to the website during its usage through the User's device's software installed, including IP address, cookie information, User browser information (or another program by which access to the site is carried out), access time, page URL.
10.3. The Operator uses non-personal information through cookies or information flow collection, performed to optimize website usage, and record visit dates and times of this website, and more. Examples of information flow collection include: — The domain name or URL address from which the user accesses the Internet; — Internet protocol address (IP); — Type of web browser used; — Date and time of visiting this website, and more;
10.4. Other information about the User, the collection, and/or provision of which is determined by the site's terms of use.
10.5. The Operator and other persons who have access to personal data must not disclose it to third parties or spread personal data without the personal data subject's consent unless federal law provides otherwise.
11. Final Provisions11.1. The User can get any clarifications on issues of interest regarding the processing of their personal data by contacting the Operator via email.
11.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is valid indefinitely until replaced with a new version.
11.3. The current version of the Policy is freely available on the internet at
https://native-call.com/.
11.4. The Operator has the right to make changes to this Privacy Policy. When changes are made to the current version, the date of the last update is indicated. The new version of the Privacy Policy comes into force from the moment it is published on the website, unless otherwise provided by the new version of the Privacy Policy. The current version of the Privacy Policy is available at:
https://native-call.com/ 11.5. This Privacy Policy and the relationship between the User and the Operator arising in connection with the application of the Privacy Policy are governed by the law of the Russian Federation as well as the legislation of the User's place of residence.
11.6. The User can change (update, supplement) the personal information provided by them or its confidentiality settings at any time by sending this information to the Operator's email.
11.7. The User can delete the personal information provided by them or part of it at any time to avoid its dissemination or transfer to third parties.
11.8. The Operator has the right to delete personal data about the User if it is no longer needed for the purposes for which it was collected, and if there are no other grounds for its storage.