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Data Protection and Cookies Policy

This document is the Data Protection and Cookies Policy (hereinafter Policy) of Satellite Innovation Limited Liability Company (abbreviated company name: Satellite LLC).

Privacy & Cookies Policy

1. Terms used in the Policy
 
Personal data is understood as any information directly or indirectly related to a certain or a definable natural person (personal data subject).
Processing of personal data is any action (procedure) or series of actions (procedures) performed with personal data with or without the use of automation aids, including collection, recording, systematization, accumulation, storage, refinement (updating, modification), retrieval, usage, transmission (propagation, submission, access), including trans-border transfer of personal data, depersonalization, blocking, deletion, and destruction of such data.
Product is understood as License, a non-exclusive (limited) right of use of the Eocortex IP camera-based video surveillance system software.
Operator is the Satellite Innovation Limited Liability Company (abbreviated company name: Satellite LLC), a legal entity that performs personal data processing.
Subject of personal data is a natural person whose personal data has been transferred to the Operator for processing.
Automated processing of personal data is understood as personal data processing aided by means of computer technology.
Preservation of the confidentiality of personal data is an obligation of the Operator or any other entity who has access to personal data to prevent its dissemination without the consent of the Subject of personal data or the existence of a legal basis.
Web site is an assemblage of data, texts, graphics, design, images, photo and video data and other results of intellectual activity, as well as computer software providing the publication of the data and information unified by a common designated use by means of the technical aids used for connecting computer equipment and the Internet. The Web Site’s address is as follows: https://eocortex.com/
User is a natural person acting for their own benefit or for the benefit of others, who has accepted the present Policy published on the Web Site and who has access to the Web Site and uses it.
Cookie is a small fragment of data sent by a web server and stored on the user’s computer. A web client (usually a web browser) sends this data fragment to the web server as part of an HTTP request at an attempt to open a page of the corresponding web site (HTTP is an application layer data protocol initially used for transferring data in the form of hypertext documents in the HTML format, now employed for transmitting any type of data). Cookies are used for storing data on the user side; however, in actual practice, they are used for user authentication, storing personal settings and preferences, monitoring user access session status, and consolidating user statistics.
Personal data dissemination is the actions aimed at disclosing personal data to the general public.
Provision of personal data is the actions aimed at disclosing personal data to a certain person or to a certain group of persons.
Blocking of personal data is a temporary stop of processing such data, apart from the cases when processing is required for the rectification of personal data.
Destruction of personal data is the actions resulting in the impossibility to recover personal data in the personal data information system and/or the destruction of physical media on which personal data is stored.
Depersonalization of personal data is the actions aimed at rendering it impossible to determine the appurtenance of the personal data to the particular Subject of personal data without using additional information.
Use of personal data is the actions with the personal data performed by the Operator in order to make decisions or perform other actions having legal implications for a Subject of personal data or other persons, or affecting the rights and freedoms of such Subject or other persons.
 
2. General Provisions
 
Referring to the Web Site as well as its use constitutes the acquaintance of the User with the present Policy and their unreserved consent with the conditions of processing their personal data stipulated in it. The Operator reserves the right to periodically modify the present Policy at its sole discretion. Should the Operator decide to make changes to the present Policy, its modified version will be published on the Web Site to enable you to always be aware of the kind of information collected by the Operator, the way it is used, and in what cases it is disclosed. The Operator uses cookie files to ensure the high-quality operation of the Web Site.
Satellite LLC and its affiliate companies are committed to the principles of protection of your personal data in Internet. We have developed our Web Site and our mobile and desktop applications in such a way as to enable you to access the majority of the materials and information without having to provide any of your personal data. However, you will have to provide your personal information in order to use certain features and processes.
In general, the Operator does not check the legal capacity of the Users or the authenticity of the personal information provided by them. However, the Operator takes as a premise that the User provides authentic and sufficient personal information in response to the relevant questions.
The present Policy is based on the following laws and regulations:
- Constitution of the Russian Federation;
- Federal Law No. 152-FZ dated June 27, 2006 entitled “On Personal Data” (hereinafter referred to as FZ No. 152-FZ);
- General Data Protection Regulation (GDPR) of the European Union (hereinafter referred to as the GDPR).
The entity responsible for data processing is Satellite Innovation Limited Liability Company.
The legal address of the Operator is as follows: Russian Federation, Perm Kray, 614066 Perm City, Shosse Kosmonavtov 111/27, Office 301.
 
​3. Principles Applicable to Personal Data Processing
 
Personal data shall be:
- processed legally, justly and transparently;
- collected for the specific, clear and legitimate purposes and not be processed in a way inconsistent with such purposes; further processing for the purposes of archiving in the public interests, with the aim of making historical or scientific investigations or for statistical purposes is not considered incompatible with the original purposes;
- adequate and relevant as regards the goals for which it is being processed, and limited by these goals;
- accurate and up-to-date, as appropriate; it is required to take all the reasonable measures to ensure that the personal data is precise and up-to-date to suit the purpose of its processing.
- stored in a format that allows to identify the Subjects of personal data during a period of time no longer than it is required for the purposes of processing such data; the personal data can be stored for a longer period, for so long as it is processed exclusively for the purposes of archiving in the public interests, with the aim of making historical or scientific investigations or for statistical purposes, as long as the corresponding technical and organizational measures are taken to protect the rights and freedoms of the Subjects of personal data;
- processed in such a way as to provide the suitable security of the personal data, ensuring the protection against unauthorized or illegal processing, as well as against accidental loss, destruction or corruption, employing the corresponding technical and organizational measures.
 
4. Rights of Subject of Personal Data
 
The right for deletion of one’s data. The User has the right to request the deletion of all their personal data without the right of its recovery to prevent the Operator from storing and, consequently, processing it.
The right to obtain a copy of User data and other information regarding such data. Each User has the right to obtain a copy of their data, including additional information.  
The right to transfer one’s data. Should the Subject wish their data to be transferred to a different company, for example, to a competing service company, the Subject has the right to demand that the company that collected their data sends such data to another company. This demand must be fulfilled free of charge.
The right to correct one’s data. The Subject of personal data has the right to demand that the Operator corrects the imprecise personal data of the Subject without undue delay. Taking into consideration the purposes of the processing of data, the Subject of personal data has the right to demand the expansion of incomplete personal data, including by providing of an additional declaration.
Other rights provided for in the legislation of the Russian Federation and the GDPR.
 
5. Data Processed by Operator
 
Any data directly or indirectly related to a certain or definable natural person (Subject of personal data) is processed. The following information, without limitation, can be attributed to such data: electronic address; full name; address: street, postcode (ZIP code), city, country (state); telephone number; project; additional data that you submit to us in your request.
 
6. Purpose of Processing of Data Listed in Section 5
 
- The maintenance of our web site requires us to process certain automatically transmitted information about you to enable your browser to display our web site and let you use it;
 
- To give you access to the personalized resources of the web site;
 
- To establish follow-up communication with you, including, but not limited to, the processing of your requests and orders;
 
- To locate you in order to ensure your safety and to prevent fraud;
 
- In order to provide you with the efficient customer and technical support in case of any problems related to the use of our web site as well as in connection with the installation and operation of our Products;
 
- In order to perform marketing activities. With your explicit consent (“I Agree” check mark in the corresponding field) or according to some other permission in obedience to the applicable legislation we will be able to use your data for promoting our products and services, or the products or services of our business partners. The following actions pertain to the marketing activities: (1) sending you newsletters, press releases, event announcements and other messages regarding our products or services; (2) sales or promotion of our products or services to you; (3) efforts to attract you to contribute to the improvement of our products and services; (4) informing you about the proposals of the third parties that, in our opinion, may interest you or your company and that are connected with our Products and services;
 
- For the purpose of processing data required for the implementation of a contract whose party, beneficiary or grantor is the Subject of personal data, as well as for concluding a contract at the initiative of the Subject of the provided personal data or a contract according to which the Subject of the provided personal data will be a beneficiary or a grantor;
 
- In order to comply with the legislation and provide for its execution. We also perform the processing of your personal data to fulfill other legal obligations that we may have in relation to the processing of your order, including, but not limited to, the retention periods according to the civil or fiscal laws. We also process your personal data to protect ourselves from any legal claims.
 
Protection of Your Data
 
Satellite LLC takes the protection of data and our responsibilities before the Users very seriously. We undertake to comply with all the relevant provisions of the legislation of the Russian Federation, the international laws and regulations, including the GDPR, with which we believe to fully comply.
We guarantee the security of the hidden contact data entered during the registration (full name / phone number). We use https encoding to ensure data transfer security.
We do not disseminate your personal data among unauthorized individuals. The above said, however, does not apply to our Web Site hosting partners and other parties that help us to maintain our Web Site, run our business and render services to our partners, provided that such parties agree to keep the said information confidential. We may also disclose the information when it is required in order to comply with the relevant legislation, to ensure compliance with the Web Site Policy, to protect our rights or those of our partners, to defend property or security. However, the data that precludes user identification may be provided to other parties for the purposes of advertising, marketing activities, etc.
We use https for safe data transfer on the Internet (Data protection by design, Article 25, Paragraph 1 of the GDPR). Using TLS (Transport Layer Security), the encryption protocol for safe transfer of data via the Internet, we are able to ensure security of confidential data. You can recognize the use of this data transfer protection by a small blocking symbol in the upper left corner of your browser and by the use of the https instead of the http in our Internet address. If you contact the Operator using electronic mail, the confidentiality of the transferred data cannot be guaranteed as the content of electronic messages may become available to third parties. For this reason, we recommend to send confidential information only by conventional mail.
 
7. Cookie Files
 
The cookie files allow the Web Site or the provider’s system to identify your browser, collect and save certain information. For example, we use cookies to save and process the information about the goods in your cart. You may forbid to use cookie files by selecting the corresponding settings in your browser, but please be aware that in such a case you will not be able to use all the features of our Web Site.
You can set up your computer in such a way that it will warn you every time a cookie file is sent, or you can disable all cookies. You can do it in your browser’s settings. Since the settings of different browsers differ, refer to the help menu of your browser to learn how to change the settings related to cookie files. 
 
8. References to Other Web Sites
 
In some cases, our Web Site will contain links to the third-party web sites. It should be borne in mind that the present Data Protection Policy does not automatically apply to the third-party web sites.
 
9. Children
 
We believe that it is imperative to provide children with additional protection online. We urge parents and guardians to spend time online with their children to observe, participate and/or control and guide their online activities. The Web Site does not perform any intentional collection of information that would allow to identify persons younger than 16 years of age. That said, in accordance with Article 8 of the GDPR, certain member states may statutorily provide lower age limit for the abovementioned purposes on the condition that it is not lower than 13. If a parent or a guardian believes that the database of the Web Site contains data that may allow identification of a child younger than the indicated age, they need to contact us and we will do everything in our power to delete any such information from our archives immediately. We do not promote our produce among the children younger than the age indicated here in any particular way.
 
10. ​Modifying the Present Policy
 
The present Policy is an internal document of the Operator. The latter, if necessary, amends the Policy unilaterally and, subsequently, publishes the amended version on the Web Site. The Subjects obtain the information regarding modifications on the Web Site independently. In case any provision of the Policy, including any sentence, item or their part, is declared contrary to the law or void, other provisions that are not at variance with the law shall remain in force and effective, but any void provision or a provision that cannot be fulfilled without further actions of the Parties shall be considered deleted, modified and corrected to the extent necessary for ensuring its validity and the possibility to be executed. Thus, we recommend you to check the Data Protection and Cookies Policy regularly to familiarize yourself with its latest version.
 
11. Our Contact Data for Follow-Up Communication
 
Should you have any questions regarding the present Policy, please contact us using the contact details below. 
Satellite LLC 
eocortex.com 
info@eocortex.com 
Russian Federation, Perm Kray, 614066 Perm City, Shosse Kosmonavtov 111/27, Office 301.
Telephone: +7 800 555 0043 (Toll-free for Russia. Billable call for CIS and foreign countries), +7 342 215 77 55 (billable call for any User).
Most recent version: September 20, 2020
 
12. Procedure of Contacting the Operator
 
The User has the right to refuse to receive electronic messages anytime by writing to us using the electronic address indicated in Section 13 of the present Policy.
At any time, the User has the right to request a deletion of all their data being processed, to forbid the use of a part or all of their data, to request the provision of the information regarding the existing data and the data being processed and make other requests using the email address specified in Section 13 of the present Policy.
The maximum term for answering is 30 days. If required, this term can be prolonged for two more months due to the complicated nature of a request or a large quantity of requests. The Operator must let the Subject know about such prolongation, stating its reason, within one month from the date of receiving the initial request. If the Subject has sent their request electronically, the reply, if possible, is also provided in an electronic form, if the Subject has not requested the information to be provided in another format. The information must be provided in a clear, brief, comprehensive and easily understandable form. Each request has to be replied to free of charge. A reasonable payment is determined on the basis of the administrative costs required for providing the answer and may only be charged when a request is deemed excessive. A Subject’s request will not be deemed excessive if they wish to receive additional copies of the data already provided, but in such a case a payment may be required. The Subject must be informed by the Operator regarding the amount to be paid, and the latter has the right to wait for the payment to arrive before providing the information. Should the Operator have a “reasonable doubt” regarding the identity of the person making a request, it may require additional information to confirm that the Operator is responding to the appropriate person. The requested information must be proportional to the purpose of completing the identification of the person and shall not fall outside the scope of such purpose.
 
13. Data Storage Term
 
The Company destroys or depersonalizes personal data when the purpose of the processing is fulfilled or when there is no more need to fulfill such purpose. You may withdraw your consent for processing your personal data by doing the following: contacting the Operator personally; sending a written request to the Operator using its address; sending an electronic message to the email of the Operator. In case you have withdrawn your consent, the Operator will still have the right to continue processing your personal data without it on the grounds stated in Items 2-11, part 1 of Article 6, part 2 of Article 10 and part 2 of Article 11 of the Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data”.
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