1. General provisions
This policy of personal data processing is made according to requirements of the Federal law No.152-FZ dated 27.07.2006 “On Personal Data” and defines the order of personal data processing and measures on providing security of personal data, undertaken by EFON RUS Ltd. (hereinafter the “Personal Data Processor”).
1.1 The Processor’s main goal and condition for its activities is to observe human and civil rights and freedoms in the personal data processing, including the protection of rights to privacy, personal and family secrets.
1.2 This Processor’s Personal Data Processing Policy (the “Policy”) applies to all information that the Processor may receive about visitors to the https://efon.ae/ website.
2. Basic concepts used in the Policy
2.1 Automated processing of personal data is the processing of personal data by means of computer technology;
2.2 Blocking of personal data means temporary suspension of personal data processing (unless the processing is necessary to clarify the personal data)
2.3 Website means a set of graphical and information materials, as well as computer programs and databases, making them available at the network address on the Internet https://efon.ae/;
2.4. Personal Data Information System means an aggregate of personal data contained in databases, and information technology and technical means ensuring processing of personal data;
2.5 Depersonalization of personal data means actions, as a result of which it is impossible to determine, without using additional information, whether the personal data belong to a particular User or another subject of personal data;
2.6 Processing of personal data means any action (operation) or set of actions (operations) with personal data performed with or without the use of automation means, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data;
2.7 Processor is a state body, municipal authority, legal entity or an individual, independently or together with other persons, arranging and (or) carrying out processing of personal data, as well as determining the purpose of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data;
2.8 Personal data is any information relating directly or indirectly to a particular or definable User of https://efon.ae/ website;
2.9. User means any visitor to https://efon.ae/;
2.10. Provision of personal data means actions aimed at disclosure of personal data to a certain person or a certain group of persons;
2.11. Distribution of personal data means any action aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication of personal data in the media, placement in information and telecommunications networks or providing access to personal data in any other way;
2.12. Cross-border transfer of personal data means transfer of personal data to the territory of a foreign state to a foreign state authority, foreign natural person or foreign legal entity;
2.13. Destruction of personal data means any action, as a result of which personal data are destroyed irretrievably with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) destruction of material media of personal data.
3. The Processor may process the following personal data of the User
3.1 Surname, first name, patronymic;
3.2 E-mail address;
3.3. Telephone numbers;
3.4 The Website also collects and processes visitors’ anonymised data (including cookies) using Internet statistics services (Yandex Metrika and Google Analytics, etc.).
3.5 The above-mentioned data hereinafter in the text of this Policy are combined with the general concept of Personal Data.
4. Purposes of Personal Data Processing
4.1 The purpose of the processing of the User’s personal data is to provide the User with access to the services, information and/or materials contained on the website.
4.2 The Processor is also entitled to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive information messages by sending an email to the Processor at email@example.com, marked “Refuse notifications about new products and services and special offers”.
4.3 The anonymised User data collected via Internet statistics services are used to collect information about the User’s activities on the website and to improve the quality of the website and its contents.
5. Legal basis for the processing of personal data
5.1 The Processor processes the User’s personal data only if the User fills in and/or sends the personal data themselves via the special forms on the website https://efon.ae/. By filling in the relevant forms and/or sending their personal data to the Processor, the Users express their consent to this Policy.
6. Procedure for collecting, storing, transferring and other processing of personal data
The safety of personal data, which the Processor processes, is ensured by implementing the legal, organisational and technical measures necessary to comply fully with the requirements of current legislation in the area of personal data protection.
6.1 The Processor ensures safety of personal data and takes all possible measures, which exclude access to personal data by unauthorised persons.
6.2 Personal data of the User shall never, under any circumstances, be transferred to third parties, except in cases related to the execution of applicable laws.
6.3. In case of identification of inaccuracies in personal data, the Users can update them on their own, by sending a notice to the Processor’s email address firstname.lastname@example.org, marked “Update of personal data”.
6.4 The time period for processing personal data is unlimited. The Users may withdraw their consent to the processing of personal data at any time by sending the Processor a notice via email to the Processor’s email address email@example.com, marked “Withdrawal of consent to the processing of personal data”.
7. Cross-border transfer of personal data
7.1 Before transborder transfer of personal data, the data controller must ensure that the foreign country to whose territory the personal data is to be transferred provides adequate protection of the rights of the personal data subject.
7.2 Cross-border transfer of personal data to foreign countries, which do not comply with the above requirements, may take place only if the personal data subject gives his/her written consent for cross-border transfer of his/her personal data and/or executes an agreement, which the personal data subject is a party to.
8. Final provisions
8.1 The User may obtain any clarifications on questions of interest regarding the processing of their personal data by contacting the Processor by e-mail at firstname.lastname@example.org.
8.2 This document will reflect any changes to the personal data processing policy of the Processor. The Policy is valid within an unlimited period until it is replaced by a new version.
8.3 The current version of the Policy is freely available on the Internet at https://efon.ae/privacy.