Privacy Policy

  • Privacy Policy

    Version 1.0 dated March 15, 2024

  • 1. Scope of Application

    • 1.1. This Policy applies to Relokator io Inc, a Delaware, corporation, company registration number:202490637456, address: 1151 Walker Road, PMB 637 Dover, DE 19904  (hereinafter referred to as the Company or Resetly) and sets forth procedures for obtaining, processing and protecting any information, including personal data of individuals (hereinafter referred to as the Personal Data Subject or Subject), within the meaning of applicable law, in connection with:
    • 1.1.1. business activities carried out in accordance with the Company's statutory documents aimed at meeting the needs of other persons (hereinafter referred to as the Service);
    • 1.1.2. implementation of employment relations;
    • 1.1.3. conclusion and execution of contractual obligations, as well as in the course of execution of any agreements and contracts relating to Personal Data Subjects.
    • 1.2. The Personal Data Processing Policy (hereinafter referred to as the Policy) is an appendix to the Privacy Policy and applies to any information including personal data of individuals (hereinafter referred to as the Personal Data).
    • 1.3. The individual who provided his Personal Data to the Company in the process of receiving the Service and using any websites (hereinafter referred to as the Website), programs, products and/or Internet services (hereinafter referred to as the Services), is a User.
    • 1.4. The main categories of processed personal data subjects are specified in Appendix 1.
    • 1.5. This Policy shall apply to:
    • 1.5.1. Resetly personnel (Resetly personnel shall mean employees under employment contracts and partners providing services to Resetly under civil contracts) (hereinafter referred to as the Personnel);
    • 1.5.2. Resetly shareholders;
    • 1.5.3. Resetly directors;
    • 1.5.4. Services users, Partners, and potential users;
    • 1.5.5. Resetly counterparties, if applicable.
    • 1.6. The requirements of the Policy shall be taken into account and applied to legal entities:
    • 1.6.1. members of the Resetly Group (hereinafter referred to as the Group Companies);
    • 1.6.2. other persons when it is necessary for them to participate in the processing of Personal Data (e.g., when data is routinely transferred from Resetly to Group Companies and other counterparties on the basis of orders for the processing of Personal Data, other agreements and contracts).
    • 1.7. The list of such legal entities is specified in Appendix No. 2 to this Policy.
  • 2. Purposes and Legal Basis of Processing

    • 2.1. The purposes for processing Personal data determine its content and scope.
    • 2.2. Resetly shall collect and use Personal data for the following purposes:

    • 2.2.1. necessity for our legitimate business interests;

    • 2.2.2. contract with Subjects to use the Services as defined in the Articles of Association;

    • 2.2.3. ensuring financial and economic activities of the Company;

    • 2.2.4. compliance to legal obligations;

    • 2.2.5. protection of its legal rights and execution of judicial and/or administrative orders, if necessary.

    •  

    2.3. Legal basis for processing personal data

    • 2.3.1. The Policy has been developed taking into account the provisions of legislation in the field of Personal Data processing, in particular but not limited to the laws of Delaware State and the European General Data Protection Regulation approved by Regulation (EU) 2016/679 of the European Parliament and of the Council dated April 27, 2016.

     

    • Purposes of Personal Data Processing

      Rights and obligations of the Company and the personal data subject

       

      2.3.2. Fulfillment of contractual obligations

      •  • provision of paid and free services to the personal data subjects;
      •  • exercise and performance of rights and obligations, including for the performance of the contract, a party or beneficiary or guarantor of which is the personal data subject, as well as for the conclusion of the contract at the initiative of the personal data subject or the contract under which the personal data subject will be a beneficiary or guarantor;

      •  • improving the quality of the services provided, as well as related services;

      •  • communicating with Subjects when necessary, including for sending notifications, information and requests related to the provision of Services, as well as for processing applications, requests and other communications received from them.

       (1) These notifications include:

      •  • payment information,
      •  • marketing and promotional notifications (mailings) about Resetly's news, products and Services (messages are sent only if the Subject consents to receive them).

       (2) At any time on a gratuitous basis the Subject has the right to refuse to receive notifications (mailings) and other information, using a special procedure of refusal of such mailings, if it does not affect the quality of the Services provided.

       

      2.3.3. Compliance with statutory requirements and obligations

      •  • execution and fulfillment of functions, powers and duties assigned as a processor (operator);
      •  • execution of a judicial act, act of another authority or official to be executed in accordance with the enforcement proceedings;
      •  • fulfillment of orders of other personal data processors.

      2.3.4. Ensuring legitimate interests

       

      •  • сarrying out activities stipulated by the Company's statutory documents;
      •  • сreation of new products and offers;
      •  • Collecting, processing and presenting statistical data and other research based on impersonal personal data;
      •  • Recruitment (selection of Personnel), including for the purpose of ensuring that candidates for vacant positions are selected for the relevant vacant
      •  • positions, and employment of successful candidates for the relevant vacant positions;
      •  • сonclusion, execution and termination of civil contracts;
      •  • exercising and fulfillment of rights and obligations arising from labor relations, including for the purpose of assisting employees in employment, education and promotion, ensuring their personal safety, monitoring the quantity and quality of work performed and safeguarding property, payment of wages and other payments due to the employee, in accordance with law or contract, as well as making tax and social deductions;
      •  • exercising the rights and legitimate interests as an operator or third parties, including protection against copyright infringement, fraud and other unfair behavior;
      •  • settlements with the personal data subjects.
  • 3. Procedure and Terms of Personal Data Processing

    • Personal Data Processing means any operation or set of operations that is performed on Personal Data or sets of Personal Data, whether or not used by automated means, such as collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, disclosure by transmission, dissemination or other provision, alignment or combination, restriction, depersonalization or destruction.
    •  

    3.1. Collection of data

    • 3.1.1. Personal data shall be collected directly from the Personal Data Subject. If provision of the requested information is mandatory in accordance with legal requirements, the Subject shall be explained the legal consequences of refusal to provide it.
    • 3.1.2. Receipt of Personal Data from other persons shall be possible only on legal grounds, and with the notification of the Subject.
    • 3.1.3. Collection and processing of Personal data that does not meet the stated purposes shall not be permitted.
    • 3.1.4. If the Subject does not wish to update Personal data or wishes to opt out of receiving newsletters (e.g., marketing), he may fill out an opt-out form and send it to the email address support@resetly.io.
    •  

    3.2. Obtaining the Subject's consent to the Personal data processing

    • 3.2.1. Personal data processing shall be carried out in accordance with the provisions of applicable law and the agreement with the Subject, after obtaining explicit and specific consent from him.
    • 3.2.2. Consent may be expressed by the Subject in the form of a contingent action, e.g.:
    • 3.2.2.1. marking, filling in the appropriate fields in the forms, blanks;
    • 3.2.2.2. electronic correspondence, which states about processing;
    • 3.2.2.3. passing to the Company's office territory after familiarization with the warning signs;
    • 3.2.2.4. other actions performed by the Subject, from which his will can be judged.
    •  

    3.3. Description of information processed on the basis of consent

    • 3.3.1. In certain cases provided for by law as well as other applicable requirements, consent shall be in writing or in standard forms.
    • 3.3.2. When processing Personal data received not from the Subject directly, but from other persons on the basis of a contract or an order for processing, the obligation to obtain the consent of the Subject shall be imposed on the person from whom the Personal data was received.
    • 3.3.3. If the Subject refuses to provide sufficient Personal data, the Company will not be able to carry out the necessary actions to achieve the purposes of the processing (for example, if the Subject does not complete the registration procedure in the Service, the Service under the contract may not be provided to him, or his resume will not be considered for a job, etc.).
    • 3.3.4. The Personal Data Subject has the right to withdraw his consent to the Personal Data processing by sending the corresponding request to Resetly or an authorized representative (DPO) by mail to support@resetly.io.
    •  

    3.4. Storage conditions

    • 3.4.1. When storing Personal data, Resetly shall follow the Standard Contractual Clauses approved by the European Commission to ensure an adequate level of protection of Personal data. The list of providers of Personal data storage Services is specified in Appendix No. 2.
    • 3.4.2. The subject located in the territory where consent is required for the transfer of his Personal data to another jurisdiction, shall provide Resetly with his explicit and unambiguous consent for such transfer or storage, and/or processing of information in other specified jurisdictions.
    • 3.4.3. Resetly shall store Personal data in the European Economic Area (hereinafter referred to as the EEA) and/or in the Russian Federation, depending on the purpose of its processing.
    • 3.4.4. Russia is a jurisdiction outside the EEA that has not been recognized by the European Commission as providing an adequate level of personal data protection, so appropriate measures shall be taken to ensure that such transfers are made in accordance with current EU data protection rules.
    •  

    3.5. Storage period

    • 3.5.1. Personal data shall be stored for as long as necessary to achieve the purpose for which it was collected or to comply with legal requirements or other regulations governing the conditions for its processing.
    • 3.5.2. A longer storage period may be required or permitted on the basis of legal requirements, as well as provided for by contractual or user agreements.

    Category

    Storage period

    • 3.5.3. Personal data subject
    •  84 months after receipt of the Service

     

    • 3.5.4. Contractor processing Personal Data
    •  one month after termination of the contract

     

     

     

    3.6. Conditions for destruction or depersonalization

    • 3.6.1. At the end of the period of storage of Personal data due to the purposes of its processing, Resetly shall do the following:
    • 3.6.1.1. deletes excess Personal Data; or
    • 3.6.1.2. depersonalizes it so that it is no longer tied to the User or the Personal Data Subject. Such depersonalized data may be used for research, statistical purposes or to improve the quality of our Services. At the same time, Resetly has the right to use it indefinitely without prior notice.

     

    Conditions for destruction or depersonalization

    Storage period

     

    Subject

    • 3.6.2. Achievement of the purpose of Personal Data processing or the maximum period of its storage
    •  within 30 days
    • Resetly

     

    • (manually or automatica lly)
    • 3.6.3. Loss of necessity in achieving the purposes of Personal Data processing
    • within 30 days
    • 3.6.4. Provision by the Personal Data Subject or his legal representative of confirmation that the Personal Data is illegally obtained or is not necessary for the stated purpose of processing
    • within 7 days

     

    • 3.6.5. inability to ensure the lawfulness of Personal Data processing
    • within 10 days

     

    • 3.6.6. Withdrawal of consent to the Personal Data processing by the Personal Data Subject, if the preservation of personal data is no longer required for the Personal Data processing
    • within 30 days

     

    • 3.6.7. Withdrawal of consent by the Personal Data Subject to use Personal Data for contacts with potential consumers in the promotion of goods and services
    • within 2 days

     

    • 3.6.8. Expiration of the limitation period for legal relations, within which Personal Data is processed or was processed

     

     

    • 3.6.9. Liquidation (reorganization) of the Company, if the processing was carried out exclusively in the interests of this organization and there is no legal successor
     
  • 4. Updating, Correcting, Deleting and Destroying Data, Responding to Subjects Requests for Access to Personal Data

    • 4.1. Resetly does not verify the Personal Data provided to it, except as provided in contractual or user agreements or in the terms of use of certain Services and cannot judge its accuracy and does not have sufficient legal capacity to provide the Personal Data.
    • 4.2. The accuracy of the Personal data and its adequacy and relevance in relation to the purposes of processing shall be ensured if it is necessary to protect the legitimate interests of Resetly. In this case, if inaccurate or incomplete Personal Data is detected, it may be clarified and updated.
    •  

    Right

    What the Subject has the right to do

    How to exercise the right

     

    Notes

     

    4.3. To get access to Personal Data

    1. To get confirmation of Personal Data processing;
    2. To get access to the Personal data, as well as information about its processing.    
    please contact the DPO

     

    The company may ask you to verify your identity before responding to a request, and in certain circumstance s may charge a fee to cover our costs.
    4.4. To correct inaccurate data To request correction of any incomplete or inaccurate data.

     

    please contact the DPO

     

    4.5. To object to processing To object to the Personal Data processing if we process it for our own legitimate interests, use it for direct marketing or for statistical purposes.
    please contact the DPO
    please contact the DPO

     

    The response time is one month after your request is received. If your request takes longer to process, we will notify you. In any
    4.6. To require us to make your data portable

     

    Under certain circumstances, to request a copy of Personal data in a structured, commonly used and machine-readable format.

     

    please contact the DPO

     

    4.7. To remove the Personal Data (in whole or in part) Under certain circumstances, to request the deletion of Personal data.
    For example, if we no longer need it, or if the Subject withdraws the consent that was the basis for processing the data.
    please contact the DPO

     


     

    contact the case, we cannot extend the response time for more than two months beyond the first month of your request.

    4.8. To withdraw consent to data processing To revoke the consent to the Personal Data processing. please contact the DPO
     
    4.9. To limit processing

     

    To ask to limit or stop the collection, use, processing and/or disclosure of Personal data.

     

    please contact the DPO
     
    4.10. To be informed about the precautions we take when transferring data to a third  country  or international organization To ask us about these measures please contact the DPO  
    4.11. To file complaints   To complain to the data protection supervisory authority about our collection and use of Personal data. please contact your local regulatory authority  

     

    • 4.12. The Subject or his legal representative may submit the request to provide/update information about the processing of his Personal data, or to delete it, but the request shall not include a requirement to provide/change data relating to other Subjects. The request of the Subject or his/her representative shall contain (at least):
    • 4.12.1. the number of the main document certifying the identity of the Subject or his/her legal representative;
    • 4.12.2. information confirming the Subject's participation in a relationship with Resetly (contract number, contract conclusion date or other information), or information otherwise confirming the fact of Personal Data processing;
    • 4.12.3. signature of the Personal Data Subject or his legal representative.
    • 4.13. Resetly has the right to reject the Subject's request to enforce rights if it is permitted or required under:
    • 4.13.1. The US and EU data protection legislation, which we shall comply with;
    • 4.13.2. the legal requirements that the data controller with whom we cooperate shall comply with.
    • 4.14. In case of rejection of the claim, Resetly shall provide a response, stating the grounds for the rejection.
    • 4.15. The subject or his or her legal representative has the right to file a complaint against our rejection with the supervisory authority.
    • 4.16. Ensuring the protection of information
    • 4.16.1. Personal data belongs to the category of confidential information and shall be protected from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions in relation to it.
    • 4.16.2. When Personal Data processing, the Company shall take reasonable and sufficient legal, organizational and technical measures, maintaining a balance between its legitimate interests and protection of confidentiality of Personal data.
  • 5. Policy Update

    • 5.1. Resetly has the right to make changes at its discretion, including, but not limited to, where the relevant changes relate to changes in applicable law.
    • 5.2. This Policy is written in English. In the event of any discrepancies or any inconsistencies in the meaning of the terms of this Policy, the English version of this Policy shall prevail.

  • 6. Policy Placement

    • Unrestricted access to this Policy and its Appendices shall be provided to all interested parties, including Personal Data Subjects and authorities exercising control and supervisory function in the field of Personal Data processing.
  • 7. Contacts

    If you have any questions, comments or requests regarding this Policy, please contact our Data Protection Officer at support@resetly.io.

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