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Personal Data Processing Policy

This is a convenience translation. The Russian version is the legally binding one

1. General provisions

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ “On Personal Data” of July 27, 2006 (the “Personal Data Law”) and sets out the procedure for processing personal data and the measures to ensure the security of personal data taken by SINKOMM LLC, TIN 7734727240, KPP 771401001, Bumazhny proezd 14 bld. 3, floor 1, premises I, rooms 23-25, 27, 127015 Moscow, Russia (the “Operator”).

1.1. The Operator’s most important goal and condition for carrying out its activities is to observe the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. This Operator’s policy on personal data processing (the “Policy”) applies to all information that the Operator may obtain about visitors to the website https://sinhron.io.

2. Key terms used in the Policy

2.1. Automated processing of personal data means processing of personal data using computer technology.

2.2. Blocking of personal data means temporary suspension of personal data processing (except where processing is necessary to clarify personal data).

2.3. Website means a set of graphic and information materials, as well as computer programs and databases that make them available on the internet at https://sinhron.io.

2.4. Personal data information system means a set of personal data contained in databases, together with the information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data means actions that make it impossible, without additional information, to determine whether personal data belongs to a specific User or other personal data subject.

2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with personal data, with or without automation, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion and destruction of personal data.

2.7. Operator means a state body, municipal body, legal entity or individual that, alone or jointly with others, organizes and/or carries out the processing of personal data and determines the purposes of processing, the scope of personal data to be processed and the 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://sinhron.io.

2.9. Personal data permitted by the subject for dissemination means personal data to which the personal data subject has given access to an unlimited number of persons by consenting to the processing of personal data permitted by the subject for dissemination in the manner provided for by the Personal Data Law (“personal data permitted for dissemination”).

2.10. User means any visitor to the website https://sinhron.io.

2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication of personal data in the media, posting in information and telecommunication networks or providing access to personal data in any other way.

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

2.14. Destruction of personal data means any actions that destroy personal data irreversibly, making it impossible to restore the content of personal data in the personal data information system, and/or destroy the physical media containing personal data.

3. Key rights and obligations of the Operator

3.1. The Operator has the right to:

  • receive accurate information and/or documents containing personal data from the personal data subject;
  • if the personal data subject withdraws consent to the processing of personal data or sends a request to stop processing personal data, continue processing personal data without the consent of the personal data subject where there are grounds specified in the Personal Data Law;
  • independently determine the composition and list of measures necessary and sufficient to fulfill the obligations provided for by the Personal Data Law and the regulations adopted under it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

  • provide the personal data subject, at their request, with information regarding the processing of their personal data;
  • organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
  • respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
  • provide the authorized body for the protection of the rights of personal data subjects, at its request, with the necessary information within 10 days from the date of receipt of such a request;
  • publish or otherwise ensure unrestricted access to this Policy on personal data processing;
  • take legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision and dissemination of personal data, as well as from other unlawful actions with respect to personal data;
  • stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
  • perform other obligations provided for by the Personal Data Law.

4. Key rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:

  • receive information regarding the processing of their personal data, except in cases provided for by federal laws. The Operator provides the information to the personal data subject in an accessible form, and it must not contain personal data relating to other personal data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
  • require the operator to clarify, block or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take measures provided for by law to protect their rights;
  • set a condition of prior consent for the processing of personal data for the purpose of promoting goods, works and services on the market;
  • withdraw consent to the processing of personal data and send a request to stop processing personal data;
  • appeal against unlawful actions or inaction of the Operator in processing their personal data to the authorized body for the protection of the rights of personal data subjects or in court;
  • exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

  • provide the Operator with accurate information about themselves;
  • notify the Operator of any clarification (updating, modification) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter’s consent, are liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. Personal data is processed on a lawful and fair basis.

5.2. Processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not permitted.

5.3. Combining databases containing personal data processed for purposes incompatible with each other is not permitted.

5.4. Only personal data that meets the purposes of its processing is subject to processing.

5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. Personal data processed must not be excessive in relation to the stated purposes of processing.

5.6. When processing personal data, the accuracy and sufficiency of personal data, and where necessary its relevance to the purposes of processing, are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows the personal data subject to be identified no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor. Processed personal data is destroyed or depersonalized once the purposes of processing have been achieved or if the need to achieve these purposes no longer exists, unless otherwise provided by federal law.

6. Purposes of personal data processing

6.1. Purpose of processing: reviewing requests submitted through the website, preparing a quote and contacting the User at their request.

Personal data: name, email address, phone number and other information from the request form at the User’s discretion.

Legal basis: consent of the personal data subject to the processing of their personal data.

Types of personal data processing: collection, recording, systematization, accumulation, storage, use, destruction and depersonalization of personal data.

6.2. Purpose of processing: analyzing website traffic and improving the website.

Personal data: IP address, cookies, information about the browser and device, information about the User’s actions on the website.

Legal basis: consent of the personal data subject to the processing of their personal data.

Types of personal data processing: collection, recording, systematization, accumulation, storage, use, destruction and depersonalization of personal data.

6.3. To collect visit statistics, the Operator uses the web analytics service Yandex Metrica (YANDEX LLC, Moscow). Yandex Metrica is enabled only after the User consents by clicking the “Accept” button in the notice on the website. The User may change this decision at any time using the “Cookie settings” button at the bottom of the website pages. If the User declines, Yandex Metrica cookies are deleted and statistics collection stops starting from the next website page opened. In addition, the User may block cookies in the browser settings.

6.4. Purpose of processing: reviewing interpreter applications, creating an interpreter account on the SINHRON platform, selecting interpreters for events and sending them invitations.

Personal data: first and last name, email address, phone number, city, Telegram username, working languages, information about work experience, education, diplomas and certificates, rates, subject areas, willingness to travel, a link to a CV or recordings, and other information from the application at the User’s discretion.

Legal basis: the consent of the personal data subject to the processing of their personal data.

Types of personal data processing: collection, recording, systematization, accumulation, storage, clarification (updating, changing), use, destruction and depersonalization of personal data.

7. Conditions for personal data processing

7.1. Personal data is processed with the consent of the personal data subject to the processing of their personal data.

7.2. Processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to carry out the functions, powers and obligations imposed on the operator by the legislation of the Russian Federation.

7.3. Processing of personal data is necessary for the administration of justice and the enforcement of a judicial act or an act of another body or official subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, as well as for concluding a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.

7.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Personal data is processed to which access by an unlimited number of persons has been provided by the personal data subject or at their request (“publicly available personal data”).

7.7. Personal data is processed that is subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for collecting, storing, transferring and otherwise processing personal data

The security of personal data processed by the Operator is ensured by implementing the legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation on personal data protection.

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

8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or where the personal data subject has given the Operator consent to transfer the data to a third party to fulfill obligations under a civil law contract.

8.3. If inaccuracies are found in the personal data, the User may update it by sending a notice to the Operator’s email address sinhron@sinkomm.com marked “Personal data update”.

8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by a contract or current legislation. The User may withdraw consent to the processing of personal data at any time by sending a notice to the Operator by email at sinhron@sinkomm.com marked “Withdrawal of consent to personal data processing”.

8.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject must review the said documents on their own and in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers referred to in this clause.

8.6. Prohibitions set by the personal data subject on the transfer (except for providing access) and on the processing or conditions of processing (except for obtaining access) of personal data permitted for dissemination do not apply to the processing of personal data in state, public and other public interests defined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator ensures the confidentiality of personal data.

8.8. The Operator stores personal data in a form that allows the personal data subject to be identified no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract to which the personal data subject is a party, beneficiary or guarantor.

8.9. Processing of personal data may be stopped when the purposes of processing have been achieved, the consent of the personal data subject has expired, the personal data subject has withdrawn consent or requested that processing stop, or unlawful processing of personal data has been identified.

9. Actions performed by the Operator with the personal data received

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (disseminates, provides, grants access to), depersonalizes, blocks, deletes and destroys personal data.

9.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the information obtained over information and telecommunication networks.

10. Cross-border transfer of personal data

10.1. Before starting cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects of its intention to carry out cross-border transfer of personal data (such notice is sent separately from the notice of intention to process personal data).

10.2. Before submitting the above notice, the Operator must obtain the relevant information from the foreign state authorities, foreign individuals and foreign legal entities to which cross-border transfer of personal data is planned.

11. Confidentiality of personal data

The Operator and other persons who have gained access to personal data must not disclose personal data to third parties or disseminate it without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final provisions

12.1. The User may obtain any clarification on matters of interest regarding the processing of their personal data by contacting the Operator by email at sinhron@sinkomm.com.

12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.

12.3. The current version of the Policy is freely available on the internet at https://sinhron.io/policy/.

13. Operator details

Name: SINKOMM LLC

TIN (INN): 7734727240

KPP: 771401001

Address: Bumazhny proezd 14 bld. 3, floor 1, premises I, rooms 23-25, 27, 127015 Moscow, Russia

Email: sinhron@sinkomm.com