PRIVACY POLICY regarding the processing of personal data
A version of "09" December 2024, Stoney Works, 8 Stoney Lane, London
1. GENERAL PROVISIONS
1.1. The Privacy Policy is developed in accordance with the UK law, defines the procedure for processing personal data and measures to ensure the security of personal data that DIGITAL SPARROW LLP may obtain about the User through the website located at the permanent URL: https://simsdynastytree.com in order to protect the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of the rights to privacy, personal and family confidentiality.
1.2. The privacy policy applies to processing the User's data, regardless of location, collected by the Operator using active or passive means, using the information and telecommunication network of general use "Internet" This data may include, but is not limited to, the User's name, email address, IP address, and browsing history. The Operator may share this data with third parties only when it is necessary to provide services or as required by law.
1.3. To access the website and use it for its intended purpose, the User has the right only after voluntarily providing specific, subject, informed, conscious, and unambiguous consent to the processing of their data on the terms defined in the Privacy Policy. This consent is provided of their own free will and in their own interests, highlighting their control over their personal data.
1.4. If the User agrees to the processing of personal data under the terms set out in the privacy policy, the User must inform the Operator in the manner specified on the website.
1.5. If the User disagrees with the processing of his data on the terms set out in the Privacy Policy, the Operator strongly urges such User to refrain from using the website, as this implies the processing of his data by the Privacy Policy. If the User wishes to withdraw his consent to the processing of his personal data, he can do so by contacting the Operator directly or by using the 'unsubscribe' link in the emails sent by the Operator.
1.6. By joining the Privacy Policy and giving consent to the processing of personal data, the Operator proceeds from the fact that the User has previously familiarized himself with the text of the Privacy Policy, the personal data is accurate and belongs to him personally, provided in an up-to-date state on the day of transfer, the User has total legal capacity and agrees to the processing of his data on the terms set out in the Privacy Policy. If the User's data changes, he is responsible for updating this information promptly by contacting the Operator.
1.7. The User voluntarily, of his own free will and in his interests, gives his specific, subject, informed, conscious, and unambiguous consent to the processing of his data on the terms provided for in the Privacy Policy, in accordance with the legislation of the Russian Federation, understands and agrees with all the legal consequences of such actions, having previously familiarized himself with his rights and obligations as a personal data subject.
1.8. In cases where the User is a person with limited legal capacity, the Operator proceeds from the fact that the consent to the processing of personal data is given by his legal representative, who has fully familiarized himself with and accepted the terms of personal data processing specified in the Privacy Policy and has sufficient authority for this purpose.
1.9. The Operator uses the following basic terms (if not expressly stated otherwise in the text) to apply and interpret the Privacy Policy. These terms may be used in a different case, in the singular or plural, with a lowercase or uppercase letter, or in the form of abbreviations:
1.9.1. "Automated processing of personal data" - processing personal data using computer technology means.
1.9.2."Blocking of personal data" is the temporary cessation of processing personal data (except in cases where processing is necessary to clarify personal data).
1.9.3."Website"- a set of computer programs, databases, graphics, audiovisuals, and information materials contained in the information system, access to which is provided through the Internet, located at the permanent URL address: https://simsdynastytree.com It includes all levels of the specified domain, both existing and introduced into operation during its entire validity term, and outgoing pages ("landing pages").
1.9.4. "Personal data information system" a system for storing personal data in databases and ensuring their processing by information technologies and technical means.
1.9.5."Depersonalization of personal data" actions as a result of which it is impossible to determine without using additional information the belonging of personal data to a specific User or another subject of personal data.
1.9.6."Processing of personal data" any action (operation) or set of actions (operations) performed with personal data using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data. For example, the User's name and email address may be collected to send newsletters or updates about the website's services.
1.9.7. "Operator" — DIGITAL SPARROW LLP Partnership No. OC454811
1.9.8."Personal data" - any information directly or indirectly related to a specific or identifiable User.
1.9.9. "Personal data allowed by the subject of personal data for dissemination" - personal data, access to which an unlimited number of persons are granted by the subject of personal data by giving consent to the processing of personal data allowed by the subject of personal data for dissemination in the manner provided by the Federal Law
1.9.10. "User" ("subject of personal data") — any individual with total legal capacity or a representative (legal representative) of another individual who has the necessary volume of rights and powers required for the conclusion and performance of the Agreement on behalf and in the interests of such individual and has provided his consent to the processing of his data.
1.9.11. "Provision of personal data" — actions aimed at disclosing personal data to a specific person or a specific circle of persons.
1.9.12. "Distribution of personal data" - any actions aimed at disclosing personal data to an indefinite unspecified number of persons (transfer of personal data) or acquainting personal data by an unlimited number of persons including disclosure of personal data in mass media, placement in information and telecommunication networks or provision of access to personal data in any other way. The Operator may transfer the User's personal data to third parties, such as service providers or business partners, to provide the User with the services and features of the website. However, the Operator will ensure that such third parties are bound by the same data protection obligations as the Operator.
1.9.13. "Cross-border transfer of personal data"- transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual, or a foreign legal entity.
1.9.14. "Destruction of personal data" - any actions resulting from which personal data are destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and/or personal data media are destroyed.
1.9.15. "Cookie files" - a small piece of data (including text files) sent by the server of a website and stored on the User's computer, which the web client or web browser sends to the server of the website in an HTTP request when trying to open the corresponding page of the website. Cookie files provide a collection of information about the User's actions on the website and track the statistics of visits to the website.
1.10. The Privacy Policy may contain other terms not provided for in this section. Therefore, the interpretation of such a term is carried out in accordance with the legislation of the Russian Federation and, in the absence of a clear definition, in accordance with business customs or scientific doctrine.
1.11. Legal basis for processing personal data: The Data Protection Act 2018 United Kingdom; Regulation (EU) 2016/679 of the European Parliament and of the Council of the European Union “On the protection of individuals with regard to the processing of personal data and on the free movement of such data and on the repeal of Directive 95/46/EU”; European Union General Data Protection Regulation (GDPR); Public offer; Privacy Policy with regard to the processing of cookies; Consent to the processing of personal data; Consent to the sending of advertising and information notices.
2. SUBJECT OF THE PRIVACY POLICY
2.1. The privacy policy sets out the Operator's obligations to keep confidential and ensure the regime for protecting the confidentiality of personal data that the User provides in connection with the use of the website, as well as the grounds, list, purposes, terms, methods, principles, procedure, and conditions for processing and storing the User's personal data, the rights and obligations of the parties, the procedure for obtaining consent and withdrawing consent to the processing of personal data.
2.2. When processing the User's personal data, the Operator ensures complete confidentiality of personal data and compliance with the requirements established by the legislation of the Russian Federation.
3. LIST OF PROCESSED PERSONAL DATA
3.1. Personal data permitted for processing under the Privacy Policy are provided by the User by filling out particular forms on the website and include the following information: last name, first name, patronymic, email address, contact phone number (mobile), nickname.
3.2. Automatically transmitted data: "cookie" files, automatic (anonymous) data from internet statistics services ("Yandex Metrica"), unique data about equipment (IP, MAC, ICCID addresses, information about the operating system of the device and browser, technical characteristics of the equipment and software, date and time of website use, referrer (address of the previous page).
3.3. The Operator uses 'cookie' files to enhance the functionality and user experience of the Website. These files allow the website to remember your preferences and settings, making your future visits more convenient. By continuing to use the site, you confirm your consent to the collection and processing of 'cookie' files.
3.4. The User holds the power to change the settings of their browser at any time, allowing them to block all 'cookie' files or receive a notification upon their sending. However, it's important to note that such actions may lead to the cessation or incorrect functioning of some functions and services of the website.
3.5. To achieve the purposes of personal data processing specified in the Privacy Policy, the Operator has the right to transfer personal data to the third parties listed below, as well as to other third parties in compliance with legal requirements.
3.5.1. Metrica is a web analytics service. Privacy Policy is published on the Internet at the permanent URL: https://yandex.ru/legal/confidential.
3.6. The Operator does not process personal data permitted for dissemination, biometric personal data, and special categories of personal data relating to racial or ethnic origin, political views, religious or philosophical beliefs, state of health, intimate life, or information about convictions.
4. METHODS AND TERMS OF PERSONAL DATA PROCESSING
4.1. We process your personal data in the following ways: through automated processes using computer technology, with the receipt and/or transfer of received data using the Internet, or without using automation tools. This includes collection, recording, systematization, accumulation and storage until the legal grounds for processing are lost and within the terms established by regulatory documents, transmission (provision, access), clarification (updating, changing), extraction, use, anonymization, blocking, deletion, and destruction of personal data.
Conducting statistical and other studies based on anonymized data, providing secure and convenient functionality for using the website, effectively displaying information, exercising and/or exercising functions, powers, providing access to services, and fulfilling other obligations.
4.2. The processing of your personal data is carried out by us in a strictly lawful manner, using the Internet and personal data information systems, using automation tools or without using automation tools, for the period necessary to achieve and exercise the purposes of processing personal data.
4.3. The Operator stores personal data with limited access for third parties by creating different levels of access to personal data in a form that allows the User to be identified. The User has the right to independently delete personal data about himself (where possible) using the website's functionality.
5. PURPOSES OF PROCESSING PERSONAL DATA AND CATEGORIES OF SUBJECTS
The Operator processes the User's personal data for the following purposes:
conclusion, execution, and termination of civil law contracts
subscription purchase processing;
order processing for subscription purchase;
subscription payment;
identification of the payer and payment;
communication and information, sending notifications of an advertising nature (by sending an email to the email address, by making a phone call in oral format and/or a text SMS message, and/or an electronic message in a messenger to the contact phone number (mobile) for the purpose of fulfilling its obligations under concluded contracts, conducting advertising or marketing campaigns, drawings, contests, surveys, sending special offers, informing about the development of new products and informing about new services, performing work to improve the quality of service provision, convenience of using the website, ordering a subscription purchase, processing an order for subscription purchase, payment for a subscription and processing payment, processing and fulfilling requests, sending other notifications, fulfilling other obligations under the contract, as well as providing technical, information, and other effective customer support);
Conducting statistical and other studies based on anonymized data, providing secure and convenient functionality for using the website, effectively displaying information, exercising and/or exercising functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation, providing access to services, and fulfilling other obligations.
5.2. Categories of data subjects processing personal data:
Users of the online service, potential Users, and their representatives;
Visitors to the website.
6. CONSENT TO THE PROCESSING OF PERSONAL DATA
6.1. The User voluntarily, of his own free will and in his interests, gives (provides) the Operator his specific, informed, conscious, and unambiguous consent to the processing of his personal data by the Operator on the terms outlined in the Privacy Policy, as follows: activating a special checkbox: "I have read and agree to the Public Offer and Privacy Policy; I consent to the processing of my personal data" in the control point of the special form on the website. This action has the legal force of written consent from the parties.
6.2. The User's consent to the processing of personal data permitted for dissemination is formalized separately from other consents to processing personal data and is provided directly to the Operator.
7. CONDITIONS AND PRINCIPLES OF PERSONAL DATA PROCESSING
7.1. Processing of User's personal data is carried out only with the consent of the User to process his personal data, provided in the prescribed manner and for the purposes defined in the Privacy Policy, taking into account the exceptions established by the legislation.
7.2. Full confidentiality of information is maintained regarding the User's personal data, except in cases where the User voluntarily provides consent to processing personal data, including those permitted for dissemination to an unlimited number of persons, and the actual provision of personal data about oneself.
7.3. As a general rule, the Operator does not disclose to third parties or distribute personal data without the User's consent, except in cases specified by the legislation and the Privacy Policy. In the case of transferring personal data to third parties, the Operator complies with the provisions of the Privacy Policy and takes measures to ensure the security of personal data.
7.4. The Operator may transfer the User's personal data to third parties in the following cases: the User has expressed consent to the processing of personal data; the transfer of personal data is necessary to achieve the purposes defined in the Privacy Policy, as well as to fulfill the Operator's obligations to the User; the legislation of the Russian Federation provides for the transfer of personal data; to protect the rights and legitimate interests of the Operator.
7.5. All information collected by other services, including internet acquisition, payment systems, communication services, and other service providers, is stored and processed by these parties (operators) according to their rules and policies. The User must independently familiarize himself with the specified documents of third parties (other operators).
7.6. The Operator is not responsible for the actions of third parties that are operators and independently process personal data (except in cases where the Operator has sent such persons a relevant instruction in the established manner).
7.7. Processing of User's personal data is organized by the Operators on the following principles:
7.7.1. Legitimacy of the purposes and methods of processing personal data, fairness, and justice of the Operator's activities. Processing of personal data is limited to achieving specific, predetermined, and legitimate goals. Processing personal data incompatible with collect personal data is not allowed.
7.7.2. Accuracy of personal data, their sufficiency for processing, and inadmissibility of collecting excessive personal data in relation to the purposes stated during the collection of personal data.
7.7.3. Collection and processing only of those personal data that correspond to the purposes of their collection and processing.
7.7.4. Compliance of the content and volume of personal data collected and processed with the stated purposes of processing. Excessive processing of personal data about the stated purposes of their processing is not allowed.
7.7.5. It is inadmissible to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
7.7.6. When processing personal data, the Operator ensures the accuracy, sufficiency, and, if necessary, relevance to the purposes of processing personal data. The Operator takes necessary measures and/or ensures their adoption for the deletion or clarification of incomplete or inaccurate data.
7.7.7. Personal data is stored in a form that allows identifying the User for no longer than is required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract, the party of which, the beneficiary or guarantor, is the User.
7.7.8. Processed personal data is destroyed or anonymized upon achieving the processing purposes or in case of the loss of the necessity to achieve these purposes unless otherwise provided by federal law.
7.8. Personal data is provided (collected) directly from the User as the subject of personal data or from a person authorized by him unless otherwise provided by federal laws.
7.9. The User independently decides whether to provide or not to provide his personal data and gives consent to their processing by the Operator voluntarily and freely, of his own free will and in his own interests.
8. RIGHTS AND OBLIGATIONS OF THE OPERATOR
The Operator has the right to:
provide the User's personal data to third parties if required by the legislation (tax, law enforcement authorities);
refuse to provide personal data in cases provided for by the legislation;
use the User's personal data without his consent in cases and to the extent provided for by the legislation;
receive from the User reliable information and (or) documents containing personal data;
in case of the User's withdrawal of consent to the processing of personal data, as well as the submission of a statement (other request) demanding the cessation of processing of personal data, the Operator has the right to continue processing personal data without the User's consent if there are grounds specified in the Law;
independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Federal Law;
exercise other rights granted to it by the legislation.
8.2. The Operator undertakes to:
provide the User, at his request, with information regarding the processing of his personal data;
organize the processing of personal data in accordance with the current legislation;
respond to requests and inquiries from Users and their legal representatives within 10 (ten) working days from the date of the request or receipt of the request by the Operator. The specified period may be extended, but not more than 5 (five) working days, in case the Operator sends a motivated notification to the subject of personal data indicating the reasons for extending the deadline for providing the requested information;
provide the necessary information to the authorized body for the protection of the rights of personal data subjects at the request of this body within 10 (ten) working days from the date of receipt of such request. The specified period may be extended, but not more than 5 (five) working days, in case the Operator sends a motivated notification to the authorized body for the protection of the rights of personal data subjects indicating the reasons for extending the deadline for providing the requested information;
publish or otherwise provide unlimited access to this Privacy Policy regarding the processing of personal data on each page of the website where personal data is collected;
provide each User with the opportunity to familiarize himself with documents and materials containing his personal data, unless otherwise provided by the legislation;
take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions concerning personal data;
stop the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in the manner and cases provided for by the Federal Law;
fulfill other obligations provided for by the legislation.
9. RIGHTS AND OBLIGATIONS OF THE USER
9.1. The User has the right to:
within 10 (ten) working days from the date of the request, receive information regarding processing his personal data, except for cases provided for by federal laws, and in some instances, within a period not exceeding 15 (fifteen) working days. The information is provided to the User by the Operator in an accessible form, and it should not contain personal data related to other Users, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Federal Law;
demand from the Operator clarification of his personal data, their blocking or destruction in case the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing, as well as take measures provided by law to protect his rights;
request a list of his personal data processed by the Operator and information about the sources of their receipt;
receive information about the processing periods of his personal data, including the periods of their storage;
demand notification of all persons to whom incorrect or incomplete personal data have been previously disclosed about all exclusions, changes, or additions made to them;
impose a condition of prior consent when processing personal data for marketing purposes;
withdraw consent to the processing of personal data, as well as submit a request to stop processing personal data;
appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in the processing of his personal data;
exercise other rights granted to him by the legislation.
9.2. The User undertakes to:
in case of a voluntary decision to transfer his personal data, provide accurate data necessary for achieving the purposes of processing personal data, and, if necessary, confirm the accuracy of personal data by presenting original documents;
inform the Operator about the clarification (update, change) of his personal data;
fulfill other obligations provided for by the legislation.
10. CROSS-BORDER TRANSFER OF PERSONAL DATA
10.1. Cross-border data transfer means the transfer of data to third parties in countries with adequate data protection and in countries that do not belong to such countries. The Operator ensures the necessary level of personal data protection by complying with the conditions specified in the Privacy Policy.
10.2. Before commencing activities related to the cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of personal data subjects of his intention to carry out the cross-border transfer of personal data (such notification is sent separately from the notification of the intention to process personal data) and to ensure that the foreign state to which the transfer of personal data is planned ensures proper protection of the rights of personal data subjects.
10.3. Before submitting a notification to the authorized body for the protection of the rights of personal data subjects, the Operator is obliged to obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. PERSONAL DATA OF MINORS AND PROTECTION OF CHILDREN'S INTERESTS
11.1. The Operator urges minors not to use the website and not to provide any information about themselves in connection with such use without the permission and participation of their parents or other legal representatives. The terms of use of the website, set out in the Privacy Policy, obligate parents or other legal representatives to provide constant and direct control over all actions of their minor children when using the website.
11.2. The Operator is committed to not processing personal data of minors without the consent of their legal representatives. The website is intended for use by individuals who have reached the age of 18. The legal representatives of minors are solely responsible for their actions on the website, including placing orders and making requests.
11.3. The Operator takes all necessary and feasible measures to prevent unauthorized use of the website by minors. If the Operator becomes aware that it has received personal data of a minor without the consent of their legal representatives, immediate Action will be taken to cease the processing of the minor's personal data.
12. MEASURES TO PROTECT PERSONAL DATA
12.1. The security of the User's personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to comply with the requirements of the Law.
12.2. The Operator ensures the confidentiality and security of the User's personal data and takes all possible measures to prevent unauthorized access to personal data, in particular, by applying the following methods:
12.2.1. Assessment of the effectiveness of measures to ensure the security of personal data before using such measures begins.
12.2.2. Detection of facts of unauthorized access to personal data and taking measures to eliminate them and prevent repeated unauthorized access.
12.2.3. Restoration of personal data modified or destroyed due to unauthorized access.
12.2.4. Establish rules for access to personal data processed in the personal data information system and ensure registration and accounting of all actions performed with personal data in the personal data information system.
12.2.5. Checking the clauses in contracts concluded by the Operator with third parties to ensure the confidentiality of personal data and, if necessary, including them in such agreements.
12.2.6. Monitoring the measures taken to ensure the security of personal data and the level of security of personal data information systems.
12.3. Third parties who have access to personal data on the Operator's instructions undertake, before the Operator, to take necessary organizational and technical measures to ensure the confidentiality of such information on their personal device from which personal data is processed.
12.4. Interaction with federal executive authorities on issues of processing and protection of the User's personal data is carried out within the framework of the legislation.
13. CONFIDENTIALITY OF PERSONAL DATA
13.1. The Operator and other authorized persons who have access to the User's personal data are obliged not to disclose or distribute personal data to third parties without the User's consent unless otherwise provided by federal laws and to take all possible measures to protect personal data from unauthorized access by third parties.
13.2. In case of establishing the fact of unlawful or accidental transfer (provision, distribution, access) of personal data to third parties, resulting in the violation of the User's rights, from the moment of detecting such an incident by the Operator, the authorized body for the protection of the rights of personal data subjects or other interested party, the Operator shall notify the authorized body for the protection of the rights of personal data subjects:
13.2.1. Within 24 (twenty-four) hours of the incident, about the alleged causes that led to the violation of the User's rights, and the alleged harm caused to the User's rights, about the measures taken to eliminate the consequences of the incident, and also provide information about the person authorized by the Operator to interact with the authorized body for the protection of the rights of the User regarding the identified incident;
13.2.2. Within 72 (seventy-two) hours of the results of the internal investigation of the identified incident, information about the persons whose actions caused the identified incident (if any) must be provided.
14. TERMINATION OF PROCESSING AND DESTRUCTION OF PERSONAL DATA
14.1. The condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the validity period of the User's consent, the withdrawal of the User's consent, the identification of the fact of unlawful processing of personal data, the liquidation or reorganization of the Operator.
14.2. The User has the right to withdraw his consent to the processing of personal data at any time, including those permitted for distribution, by sending a revocation to the Operator in the form of an electronic document to the email address info@simsdynastytree.com info@simsdynastytree.com with the subject of the email: "Revocation of consent to the processing of personal data". The User's consent to the processing of personal data ceases to be valid from the moment the Operator receives the revocation of consent.
14.3. In case inaccurate personal data are identified, the User must update them independently by sending an electronic document requesting the Operator to update personal data to the email address info@simsdynastytree.com, info@simsdynastytree.com with the subject line "Update of personal data".
14.4. In case of inaccurate personal data identification, the Operator, at the User's request, is obliged to block the personal data related to the User from the moment of such request and for the period of verification if blocking personal data does not violate the rights and legitimate interests of the User or third parties.
14.5. If the Operator confirms the fact of the inaccuracy of personal data, it is obliged to clarify the personal data within 7 (seven) calendar days from the date the User submits clarified (updated) personal data and remove the block from the User's personal data.
14.6. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the latter's consent bear responsibility in accordance with the legislation.
14.7. Upon achieving the purpose of processing personal data, the Operator terminates the processing of personal data (or ensures its termination) and destroys personal data (or ensures its destruction) within a period not exceeding 30 (thirty) calendar days from the date of achieving the purpose of processing personal data.
14.8. Personal data on electronic media is destroyed by erasing and/or formatting the media, and documents (material media) containing personal data are destroyed by burning, crushing (shredding), or chemical decomposition.
14.9. After the destruction of personal data, the Operator prepares a Certificate of Destruction of Personal Data and/or ensures and keeps a printout from the event log in the information system (accounting or personnel program, corporate website, other similar computer program or other data collection and storage source).
14.10. If the Operator identifies the unlawful processing of personal data, it is obliged to stop the unlawful processing within 3 (three) calendar days from the date it identifies the fact.
14.11. If it is impossible to ensure the lawfulness of the processing of personal data, the Operator is obliged to destroy such personal data within 10 (ten) calendar days from the date of identifying the unlawful processing of personal data and notify the User of the elimination of violations or the destruction of personal data.
14.12. The Operator has the right to continue using the User's personal data after considering the withdrawal of consent to the processing of personal data by ensuring the anonymization of such information in cases provided for by federal laws.
15. DISPUTE RESOLUTION PROCEDURE
15.1 Within 30 (thirty) calendar days from the date of receipt of the claim, the Operator shall notify the claimant in writing of the results of its consideration. This period may be extended, but not more than 15 (fifteen) calendar days, in case the Operator sends the User a motivated notification indicating the reasons for extending the deadline for responding to the claim.
15.2 If the parties fail to reach an agreement, the dispute shall be submitted for consideration to the judicial authority at the Operator's location.
16. FINAL PROVISIONS
16.1 The privacy policy applies to all legal relations between the Operator and the User in the collection, processing, and protection of personal data and applies to all collected and processed personal data. All issues related to the collection and processing of personal data not regulated by the Privacy Policy are resolved by the legislation.
16.2 The Privacy Policy remains in effect indefinitely until a new edition is adopted. Changes or additions to the Privacy Policy are made in the event of changes in the scope, method, or procedure for processing personal data, the introduction of new legislative acts, or special regulatory documents on the processing and protection of personal data. These changes are implemented by amending the Privacy Policy directly, followed by the publication of the new edition and the indication of the publication date, ensuring the User is informed of any updates.
16.3 The User, as the owner of their personal data, has the right to fully exercise all his rights as a personal data subject and receive explanations on the issues of interest regarding the collection, processing, and protection of his personal data by contacting the Operator at the email address info@simsdynastytree.com. info@simsdynastytree.com
16.4 The original copy of the Privacy Policy is kept at the Operator's location.
16.5 Access to the Privacy Policy is open to the User 24/7 without the need to fulfill additional conditions, except in cases where the website is not available for technical reasons.
16.6 The privacy policy is drawn by the legislation. The Privacy Policy is published on the website of the World Wide Web at the permanent URL: https://simsdynastytree.com in the "Privacy Policy" section to ensure unlimited and unrestricted access to it for all Users.
ATTACHMENTS
No. 1: "Cookie Policy".
No. 2: "Consent to the Processing of Personal Data".
No. 3: "Consent to Receive Advertising and Informational Notifications".
PRIVACY POLICY regarding the processing of "cookie" files
(from now on referred to as the "Policy")
1. General provisions
1.1. This Policy is drawn up by the requirements of Federal Law. It defines the procedure for processing, managing, blocking, and deleting "cookie" files and the types and purposes of processing "cookie" files collected by the Operator using the website.
1.2. "Cookie files" are small pieces of data (including text files) sent by a website server and stored on a User's computer, which the web client or web browser sends to the website server in an HTTP request each time an appropriate website page is opened. "Cookie" files collect information about the User's actions on the website and track website visit statistics.
1.3. This website uses "cookie" files to implement and improve the website's functionality, ensure financial security, promote the website, attract new customers, and provide quality service. The Operator uses the information obtained from "cookie" files to the extent necessary to achieve the purposes of their use.
1.4. The User may encounter embedded content, or the User may be redirected to other websites for specific activities. These websites and embedded content may use their own "cookie" files. The Operator does not control other websites' placement of "cookie" files, even if the User is redirected to them from this website.
1.5. The Operator processes anonymized data about the User if permitted in the User's browser settings (enabled saving of "cookie" files and use of "JavaScript" technology).
1.6. To inform the User and obtain his consent, the Operator places the following notification on the website: "We use cookies for quick and convenient website operation. By continuing to use the site, you confirm your consent to collect and process cookie files".
2. Type and purpose of "Cookie" files
2.1. The website collects and processes anonymized data about visitors (including "cookie" files) using internet statistics services ("Yandex Metrica"), which are necessary for the operation of "Yandex" services, as well as data necessary for promoting the website in search engines.
2.2. Yandex Metrica is a web analytics service provided by Yandex that uses the data collected to track and study the use of a website, prepare reports on its activities and share them with other Yandex services. Information collected: cookies and usage data. For more details, go to the “Privacy Policy” on the page https://yandex.ru/legal/confidential . The user can refuse the transfer of data to “Yandex Metrics” by installing the “Blocker” from “Yandex Metrics”.
2.3. When visiting and using the website, the Operator uses the following types of "cookie" files: essential (mandatory, strictly necessary), analytical and operational, internet statistics services, target (advertising), and social networks.
2.4. Essential (mandatory, strictly necessary) "Cookie" files are necessary for the functioning and correct operation of the website and its essential functions and, therefore, cannot be disabled in our systems. Typically, they are activated only in response to actions taken by the User, such as requesting access to an online service or filling out forms. The User can configure the browser to notify them about their use or block these "cookie" files, but in this case, some sections of the website may not work correctly.
2.5. Analytical, operational, target "Cookie" files: allow us to count visits and traffic sources to assess and improve the performance of our website. These "cookie" files are used to collect information about traffic to the website and how the User uses our website. Thanks to them, we know which pages are the most and least popular and see how the User navigates the website. All data collected using these "cookie" files is aggregated into statistics, making it anonymous. The collected information does not identify any individual visitor. The information is aggregated and anonymous. If the User disapproves (prohibits) the use of these "cookie" files, we will not have data about the User's visits to our website.
2.6. Social networks ("Cookie" files): are used to work with and interact with social networks and messengers ("WhatsApp","YouTube"). They are configured for social network services, and messengers are added to the website, allowing users to navigate to other community pages or share their progress. Such files can track the User's actions in the browser on other websites and collect data about their interests. This file type can affect the materials and messages the User sees on other visited websites.
2.7. Data automatically transmitted during the use of the website, including but not limited to unique equipment data (IP, MAC, ICCID addresses, information about the Type of device operating system and browser, technical characteristics of equipment and software, date, time of website use, and referrer (address of the previous page). This data is necessary for processing Subscription purchases and ensuring the correct operation of the website's basic functionality, improving service quality and content personalization, tracking visit statistics, advertising, and promoting the website in search engines.
3. Managing "Cookie" files, Blocking, and Deleting Them
3.1. The User can disable "cookie" files in the settings of their internet browser. To delete "cookie" files set by the website and other sites, the User should follow the instructions on the browser's help pages or the website.
3.2. The User can block "cookie" files by activating a specific setting in the browser, allowing the User to refuse to install all or some "cookie" files. However, if "cookie" files are blocked in the internet browser, the User may lose access to all or some functions (sections) of the website.
3.3. The User can clear all "cookie" files set by the website they have visited.
3.4. If the User purchases a new device (gadget), installs or updates the internet browser, erases or otherwise modifies the "cookie" files of their internet browser, this may also result in the clearing of "cookie" files.
4. Final Provisions
4.1. If the Operator changes the use of "cookie" files, the corresponding changes will be made to this Policy regarding processing "cookie" files. If the User has any questions or suggestions regarding this Policy, they can inform the Operator by emailing the email address.
CONSENT for personal data processing
The User, acting voluntarily, of his own free will and in his interests, provides specific, focused, informed, conscious, and unambiguous Consent to the processing of his personal data by DIGITAL SPARROW LLP by the law, to protect the rights and freedoms of man and citizen when processing his personal data using the website located at the permanent URL: https://simsdynastytree.com including the protection of rights to privacy, personal and family secrets, on the terms set out below:
1.Purposes of Personal Data Processing: conclusion, execution, termination of civil contracts; registration of Subscription purchase; processing of Subscription purchase orders; payment for Subscription; identification of payer and payment; communication and information, sending notifications of an advertising and informational nature (by sending an email to the email address, by making a phone call in oral format and/or sending a text SMS message, and/or an electronic message in a messenger to the contact phone (mobile) for the purpose of fulfilling its obligations under concluded contracts, conducting advertising or marketing campaigns, lotteries, contests, surveys, sending special offers, informing about the development of new products and informing about new services, conducting work to improve the quality of service provision, ease of use of the website, processing of Subscription purchase orders, payment for Subscription, and processing of payment, processing and execution of requests, sending other notifications, fulfilling other obligations under the contract, as well as providing technical, informational, and other effective customer support); conducting statistical and other studies based on anonymized data, providing safe and convenient functionality for using the website, effective display of information, implementation and/or execution of functions, powers, and obligations imposed on the Operator by the legislation, ensuring access to services and fulfilling other obligations.
2. List of Processed Personal Data: last name, first name, patronymic, email address, contact phone (mobile), nickname. Automatically transmitted data: "cookie" files, automatic (anonymous) data from internet statistics services ("Yandex Metrica"), unique data about equipment (IP, MAC, ICCID addresses, information about the type of device operating system and browser, technical characteristics of equipment and software, date and time of website usage, referrer (address of the previous page).
3. To achieve the purposes of processing personal data specified in the Privacy Policy, the Operator has the right to transfer personal data to the third parties listed below, as well as to other third parties, in compliance with the requirements of the legislation:
3.1.1. LLC "Yandex" - Yandex Metrica is a web analytics service. The privacy policy is published online at the permanent URL: https://yandex.ru/legal/confidential.
4. The Operator does not process personal data allowed for distribution, biometric personal data, and special categories of personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, health, intimate life, or information about convictions.
5. List of actions with personal data for which Consent is given, a general description of the Operator's methods of processing personal data used: automated processing of personal data using computer technology, with receipt and/or transmission of received data using the Internet, or without using automation means: collection, recording, systematization, accumulation, storage until the legal grounds for processing are lost and within the terms established by regulatory documents, transfer (provision, access), clarification (updating, changing), extraction, use, anonymization, blocking, deletion, destruction of personal data.
6. Method of providing User's Consent to the processing of his personal data: activation of a particular checkbox: "I have read and agree to the Public Offer and the Privacy Policy, I give my consent to the processing of my personal data" in the control point of the particular form on the website. This action has the legal force of written Consent from the parties.
7. Method of revocation by the User of his Consent to the processing of his personal data: sending an electronic document to the Operator at the email address info@simsdynastytree.com, with the subject of the email: "Revocation of consent to the processing of personal data," with a request to stop processing personal data. info@simsdynastytree.com Privacy.attachment2.text9-2
8. Personal Data Processing Period: from the date of giving Consent to the day of revocation of Consent to the processing of personal data. In other cases, the processing period is determined by achieving the purposes for which personal data were collected unless otherwise provided by the legislation. The User's personal data shall be stored for the periods established by the legislation.
Grounds for the termination of personal data processing and their destruction: achievement of processing purposes, withdrawal of Consent, identification of the fact of unlawful processing, liquidation or reorganization of the Operator, expiration of the consent period. The Operator terminates the processing of personal data (or ensures its termination) and destroys personal data (or ensures their destruction) within a period not exceeding 30 (thirty) calendar days from the date of occurrence of at least one of the specified grounds.
10. Method of personal data destruction: Personal data on electronic media are destroyed by erasing and/or formatting the media. Documents (material carriers) containing personal data are destroyed by burning, shredding (grinding), or chemical decomposition.
11. After the destruction of personal data, the Operator draws up an act of destruction and/or ensures and preserves the extraction from the event log in the information system (accounting or personnel program, corporate website, other similar computer program, or other source of data collection and storage).
12. The User confirms by his Consent that he has been previously acquainted with and agrees to the terms of the Privacy Policy, his rights, and obligations in the field of personal data processing, understands all legal consequences arising from giving Consent, and also confirms that the Operator has the right to process his personal data on the terms defined in the Privacy Policy and this Consent.
CONSENT to receive advertising and informational notifications
(from now on referred to as the – "CONSENT")
The User, exercising their autonomy, voluntarily and in their own interests, provides specific, informed, conscious, and unambiguous consent to Individual Entrepreneur Vorobyev Dmitry Viktorovich to receive advertising and informational notifications. This consent is by Federal Law and is subject to the terms defined in the Privacy Policy and this Consent.
1. The Operator has the right to send the User advertising and informational notifications without limitation of volume (quantity), time of day, and period of distribution, in the manner and method and for the purposes provided for in the Privacy Policy and this Consent.
2. Distribution methods: automated distribution or without the use of automation tools, in oral format through a phone call and/or text (SMS) message, and/or electronic message in a messenger to the contact phone number (mobile), and/or by sending an email to the email address.
3. Purpose of distribution: conclusion, performance, termination of civil contracts, conducting advertising or marketing campaigns, lotteries, contests, surveys, sending special offers, informing about the development of new products and informing about new services, improving the quality of service provision, improving the convenience of using the website, as well as fulfilling other obligations.
4. Advertising and informational notifications may be sent to the User personally by the Operator or with the help of third parties who participate in message delivery technical support based on contracts concluded with the Operator.
5. The Operator has the right to send advertising and informational notifications on behalf of and in the interests of its partners.
The User's consent to receive advertising and informational notifications is given as follows: by activating a particular checkbox: "I have read and agree to the Public Offer and Privacy Policy, I consent to the processing of my personal data" in the control point of the particular form on the website. This action has the legal force of written consent to receive advertising and informational notifications for the parties.
6. The User retains the right to withdraw their consent to receive advertising and informational notifications at any time. This can be done by submitting a revocation of consent to the Operator as an electronic document to the email address: info@simsdynastytree.com with the subject line: "Withdrawal of consent to receive advertising and informational notifications". The consent to receive advertising and informational notifications will no longer be valid when the Operator receives the revocation of consent.
ADMINISTRATION DETAILS
Name:
DIGITAL SPARROW LLP Partnership No. OC454811
Address:
STONEY WORKS 8 STONEY LANE LONDON UNITED KINGDOM SE19 3BD