Privacy Policy
of navi-genius.com
NaviGenius LTD
This Privacy Policy ("Policy") governs the collection, use, disclosure, transfer and storage of personal information of Clients, which the company NaviGenius LTD. (hereinafter referred to as the Data Controller or NaviGenius LTD ), receives about the Client when the Client uses the website https://navi-genius.com/ (hereinafter referred to as the "Site").
- General information
The content of the website https://navi-genius.com/ is the exclusive property of NaviGenius LTD.
The Controller controls and ensures the processing of personal data in strict accordance with the principles and legislation relating to the protection of personal data, in particular the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data since April 27, 2016
The processing of personal data is carried out entirely on a legal basis for the purpose of providing information to individuals, concluding and executing contracts, in accordance with the following principles:
- conscientiousness and reasonableness in the processing of personal data;
- transparency and legitimacy;
- the processing of personal data is limited to the achievement of specific goals provided for by these rules and agreements concluded with the Client;
- only the minimum necessary amount of personal data is processed, which is required to achieve the goals provided for by these rules and contracts;
- security and limitation of storage.
NaviGenius LTD may update this Privacy Policy, and in this case the company will notify data subjects via the Site of any changes before they become applicable.
- Definitions
" Personal data " - any information about the Client that can identify them directly or indirectly, by reference to an identification element, such as name, title, identification number, location data, online identifier or one or more particular elements specific to their physical, physiological, psychological, economic, cultural or social identity.
" Client " - a person who performs any actions on the Site and is also a consumer of NaviGenius LTD services, regardless of the use of the Internet including when concluding an agreement with him.
" Processing " - means any operation or set of operations performed on Personal Data, including, without limitation, their collection, registration, storage, modification, use, disclosure, access, transfer or destruction.
“Privacy Policy of personal data” is a mandatory requirement for compliance by NaviGenius LTD or other persons who have access to personal data to prevent its distribution without the consent of the subject of personal data, unless there is another legal basis.
"Cookies" - a fragment of data sent by the web server and stored on the Client's computer, which the web client or web browser sends to the web server in an NTTR request each time the Client attempts to open a page of the corresponding website.
"IP-address" - a unique network address of a node in a computer network built according to the protocol.
III. Categories of personal data (subject of confidentiality)
The categories of Personal Data processed depend on the context of interactions and relations between the Controller and the Client. Thus, the Controller may process the following categories of personal data:
- For visitors of the Site , the name, gender, age, date of birth, data arising from an identity document including a copy of the document, as appropriate), address, telephone, e-mail, marital status, nationality, signature, profession may be processed. , occupation, bank information, contract information, also the name, location, credentials and other data;
- For contact request: name, surname, e-mail address, title, location, credentials;
- In case of a contract conclusion: name, surname, e-mail address, telephone number, position, city, CV (which may be included, among other things, the following data in addition to those mentioned above, respectively: photo, professional training, information about current work), name, location, credentials;
- For newsletter subscribers - name, surname, e-mail address, title, location, credentials.
- Data received by NaviGenius LTD independently: the source of access to the Site and search query information, data about the user device (including resolution, version and other attributes, characterizing the user device), user clicks, page views, field fills, shows and views of banners and videos, data characterizing audience segments, session parameters , visit time data , Client identifier stored in the Cookies , and Client's IP-address.
The above-mentioned personal data of the Privacy Policy can be provided by the Client to NaviGenius LTD by any means, including electronic communication channels, via the Internet, by phone, on paper, orally.
- Purposes and grounds of personal data processing
Personal data of Clients may be processed by NaviGenius LTD directly and/or through authorized persons on the basis of the following purposes and grounds:
- providing Clients with information (including advertising) about the services provided by NaviGenius LTD by telephone, SMS, notifications, e-mail;
- compliance with the internal rules of NaviGenius LTD and adherence to the provisions of European / national standards concerning the requirements for quality and competence of services;
- performing financial, accounting and fiscal duties, including preparation of accounting records, maintenance of supporting documents underlying accounting records;
- resolving issues related to the implementation of the rights enjoyed by the Client in the context of data processing;
- internal audit;
- archiving of documents in accordance with legal regulations and compliance with the conditions of the archival nomenclature approved by the competent authority;
- managing relationships with government agencies or other organizations providing public services;
- fulfillment of contractual obligations under agreements concluded between NaviGenius LTD and the Client;
- preparation and publication of scientific articles in official and electronic editions.
- Recipients of personal data and processing
For processing purposes, the Data Controller may disclose certain categories of Personal Data to the following categories of recipients:
- data subject and / or their legal representatives;
- Representatives of NaviGenius LTD, persons whose Group includes the Data Controller.
- Authorized personnel of NaviGenius LTD in various fields (such as security services, archiving services, marketing agencies);
- other service and product providers involved in the activities of NaviGenius LTD (such as external consultants in various fields such as accounting, law, taxes), professional organizations, market research organizations;
- judicial authorities or other public authorities of any kind, international organizations.
NaviGenius LTD uses the following types of personal data processing: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, - provision, access), depersonalization, pseudonymization, blocking, deletion, destruction of personal data.
NaviGenius LTD has the right to carry out automated, non-automated and mixed processing of personal data. In the process of processing personal data, a Client profile may be compiled, which is necessary for the provision of services.
Clients' requests for information about personal data processed by NaviGenius LTD, as well as requests for blocking, changing, clarifying or deleting personal data are sent by personal data subjects by e-mail, or by post or courier. Requests are sent from the e-mail address previously provided by the personal data subject to NaviGenius LTD, or with the Client's passport data attached (number of the passport or other main identification document of the personal data subject, information about the date of issue of the said document and the issuing authority).
NaviGenius LTD considers requests of personal data subjects and sends answers to them within 30 (thirty) days from the moment the request is received.
Requests to change incomplete, inaccurate or outdated personal data, as well as requests to delete data that have been illegally obtained by NaviGenius LTD or do not meet the stated purposes of processing, shall be considered within 7 (seven) business days.
NaviGenius LTD's response to the personal data subject's request is sent to the address specified by the Client in the corresponding request.
- Duration of personal data processing
The Data Controller will process the Client's Personal Data for the period necessary for the purposes of processing and thereafter in accordance with NaviGenius LTD's internal policy, and in order to comply with applicable legal obligations, including, but not limited to, provisions regarding the obligation to archive.
VII. Transfer of personal data
Personal data provided by NaviGenius LTD may be transferred to the EU and CIS countries.
VIII. Security of personal data
The Controller attaches great importance to the confidentiality and security of Clients' Personal Data and guarantees their security during processing. In this regard, the Controller takes appropriate technical and organizational measures to ensure a level of security appropriate to the risks associated with the types of data processed and processing operations.
As part of the protection of personal data from unauthorized access, NaviGenius LTD ensures such a security regime for the premises where personal data information systems are located, which prevents the possibility of uncontrolled penetration of third parties into such premises, determines the list of persons whose access to personal data is necessary to perform their official duties, applies anti-virus protection of personal data processing information systems, backs up personal data databases, appoints a person responsible for ensuring the security of personal data.
- Provision of personal data
Provision of Personal Data is a necessary condition for using the services provided by NaviGenius LTD, concluding contracts, using the Site and other opportunities. In some cases, refusal to provide Personal Data may result in the inability to receive services provided by NaviGenius LTD, including those provided through the Website (for example, the impossibility of registering a request).
- Rights of the data subject
With regard to the processing of Personal Data referred to in this Privacy Policy, each data subject shall have the following rights in accordance with the applicable legal provisions:
- right to information - the right to receive information about the processing carried out by the Holder, in accordance with the requirements of the law;
- right to access to data - the right to receive from the operator of personal data, upon request and under the conditions established by law, confirmation that the data relating to them is processed or not processed by the operator of personal data, as well as details regarding data processing;
- right to correction - the right to correction by the operator of inaccurate personal data;
XI . Questions about the NaviGenius LTD Privacy Policy
For questions regarding privacy policy, User may contact NaviGenius LTD via the website navi-genius.com