Consent to the Processing of Personal Data and Privacy Policy

This consent regulates the legal relations arising in connection with personal data processing between the parties, where one party provides its data to the other for processing.

The law sets out the rules, principles, grounds, and security measures that must be followed when processing personal data of individuals.

To determine whether the law has been violated, each case should be approached individually on the basis of legal regulations. However, there are two basic conditions that are always necessary for lawful data processing: the existence of a legal basis and the established legal grounds for processing data.

Legal grounds are what make data processing permissible. Data processing is permissible if:

a) There is consent from the data subject — a voluntary, informed, and explicit consent to processing their personal data; for example, acceptance of a privacy policy posted on a website, or signing an agreement that clarifies what data will be collected, for what purpose, etc.;

b) Data processing is provided by law;

c) Data processing is necessary for the data processor to fulfill its obligations under the law;

d) Data processing is necessary to protect the vital interests of the data subject;

e) Data processing is necessary for the protection of the data processor's or third-party interests, except where there is an overriding interest of protecting the rights and freedoms of the data subject;

f) According to the law, the data is publicly available or the data subject has made it publicly available, for example, any statement posted by you on social media;

g) Data processing is necessary to protect important public interests in accordance with the law;

h) Data processing is necessary to consider the data subject's request or provide them with services.

When it comes to processing special categories of data, the law sets higher standards and provides different grounds for processing such data.

Processing of special categories of data is permissible only with the written consent of a data subject or when:

a) Processing data related to criminal convictions or health status is necessary for employment relations and based on the nature of the relationship, including, without limitation, for hiring decision-making;

b) Data processing is necessary to protect the vital interests of the data subject or a third party and the data subject is physically or legally unable to give consent to data processing;

c) Data is processed by a public health institution, healthcare facility or worker for the purposes of protection of an individual's health, or where it is necessary for managing or functioning of a healthcare system;

d) The data subject has made their personal data publicly available without explicit prohibition on its use;

e) Data is processed by a political, philosophical, religious, or professional association or a non-profit organization for legitimate purposes. In such cases, data processing can only relate to members of the association/organization or those having a continuous relationship with them;

f) Data processing is carried out for the purpose of maintaining a register of personal files and a register of accused/convicted persons, individual planning of sentence execution, and/or parole release of a convicted person from an unserved sentence and substituting a lesser sentenced for their unserved part of the original one;

g) Data processing is necessary to comply with a valid subpoena, court order, or other lawful request from a law enforcement, regulatory, or governmental authority in the United States, or to establish, exercise, or defend legal claims;

h) Data is processed for the purposes of operation of a unified migration data analysis system;

i) Data is processed to implement the right to education for individuals with special educational needs.

In order to avoid violating the law during data processing, there must be at least one legal ground.

Principles of Data Processing

For lawful data processing, it is not enough to have a legal ground. Data processing must be carried out according to specific principles. Like the grounds, the principles are prescribed by law.

Fairness and Lawfulness – Personal data must be processed fairly and lawfully, without infringing the dignity of the individual.

Specific Legal Purpose – There must be a clear, defined purpose for processing the data. Using data for any other purpose is prohibited.

Proportionality and Adequacy – Data should be processed to the minimum extent necessary to achieve the specific purpose of processing and must be appropriate for the stated purpose.

Authenticity and Accuracy – Data must be accurate and authentic, and if necessary, updated. Data collected without legal grounds and irrelevant to the processing purpose should be blocked, deleted, or destroyed.

Storage Duration – Personal data must be stored for the period prescribed by law or for as long as necessary to achieve the purpose. After achieving the purpose, data must be deleted or stored in a form that prevents identification of the individual, unless otherwise prescribed by law.

To ensure that data processing does not violate the law, all the five principles defined therein must be adhered to.

Disclosure of Personal Data

Personal data may only be disclosed in cases provided by applicable law. This includes instances where a third party requires disclosure in accordance with statutory requirements, such as disclosure of personal forensic information or for the protection of your or others' vital interests, such as in case of an emergency or an imminent threat to life.

Data Processing and Retention Period

We will store and process your personal data for the purposes outlined in this document, for the duration necessary to perform the activities mentioned herein, or for a period otherwise communicated to you, or for the period permitted by applicable law. For example, we may store your personal data if required for legal obligations, legal requirements, disputes, or judicial/arbitration/mediation processes.

Unless otherwise prescribed by applicable law, the maximum retention period for personal data is 3 (three) years from the date of receipt and initial processing. After the expiration of this three-year period, such personal data will be deleted or otherwise destroyed.

Please note that you have the right to withdraw your consent to the processing of personal data at any time by sending a written notice. In such a case, the company will cease processing the personal data for which you have withdrawn your consent.

Legislation

This document shall be governed and interpreted under the applicable laws of the United States, including the Delaware Personal Data Privacy Act (6 Del. C. § 12D).

Consent to this Policy

By acknowledging this Policy, you recognize that this Personal Data Processing Policy is part of our Terms and Conditions, and by providing your consent, you unconditionally agree that by registering through the application or on the website and becoming a user, you agree to the data processing policy applicable to your personal information.

Cookies and Automatic Logging

What are cookies?

Cookies are small pieces of data (text files) that a website asks the browser on your computer, tablet or mobile device to store. Cookies allow websites to recognise your device. They hold information about your activity on the website and may also contain details about your equipment and the date and time of your session. Cookies are stored locally on your computer or mobile device. We process usage data (location details; operating system type and version; browser type and version; device type and screen resolution; the source you arrived from — which website or which advertisement; operating system and browser language; the pages you open and the buttons you click; IP address) in order to operate the website, run retargeting and carry out statistical research and analysis. You can delete stored cookies at any time in your browser settings.

How we use your cookies

Like most other organisations' information resources, our web servers and security systems store some temporary technical data in their log files from time to time.

We use cookies to collect information automatically and to improve the quality of our content. We also use cookies to identify your preferences so that we can learn about your need for the services provided by our partners.

How we process your cookies

Our website processes the data it receives using measurement tools and analytics systems such as Yandex Metrica and the retargeting pixels of analytics services.

We use the cookies of such third-party services for statistical, analytical and marketing purposes. Personal data collected by web analytics services is processed only after the website user has given prior consent to the processing of personal data by accepting the cookie terms (clicking «OK» on the cookie banner).

The personal data processed for this purpose does not belong to special categories and is not biometric data under applicable law, and it is processed by automated means. The cookies that are set are stored by the browser and remain valid for different periods depending on their type. They may last until the end of the session, until you clear your browser, or indefinitely. You can refuse the cookies of third-party analytics services through the relevant settings in your browser.

What types of cookies do we use?

Session cookies exist in temporary memory for as long as you stay on a page of the website. Browsers usually delete session cookies once you close the website window. Session cookies allow the website to remember the choices you made on a previous page so that you do not have to enter the same information again.

Persistent cookies are stored on your computer and are not deleted when you close the browser. Persistent cookies can save your settings for a particular website so that these preferences can be reused in future browsing sessions. Such cookies allow us to identify you as a unique user of the website and, when you return, help us recall information about you and the actions you took earlier.

Statistical cookies help website owners understand how visitors interact with websites by collecting and reporting information anonymously.

Analytical and marketing cookies record how you use the website — for example, which pages you visit and which links you follow. The main purpose of such cookies is to improve the features and performance of the website; they also let us show visitors relevant offers and improve their experience.

Strictly necessary cookies are the minimum set of cookies required for the website to work correctly.

When you use our services, the following information about you becomes available to us: IP address, location (country or city), the type and version of your device's operating system, the type and version of the browser on your device, the device type and its display resolution, your traffic source, the language of your operating system and browser, and data about your activity online. These technologies are used to track your behaviour on the website in general in order to improve the services we provide.

The data collected through cookies does not belong to special categories and is not biometric data under applicable law, and it is processed by automated means.

Like most other organisations' information resources, our web servers and security systems store some temporary technical data in their log files.

Cookies collected on our website:

How can you refuse cookie processing?

If you do not want us to collect your data through cookies, you can disable them in your browser settings. In that case the website will use strictly necessary cookies only. You can read more about this in the help pages of Google Chrome, Mozilla Firefox, Safari and Microsoft Edge.

How to contact us

If you have questions about the processing of your personal data or wish to exercise your rights as a data subject, please write to us at info@proxy.market

Email newsletters

To run email campaigns and to send notifications and informational messages, we use the UniSender service (Unisender Smart LLC, https://www.unisender.com).

When you subscribe to a newsletter or leave your contact details on the website, your personal data (name, email address, phone number and any other data you provide in the form) may be transferred to UniSender for processing in order to:
— send informational and promotional newsletters;
— notify you about news, campaigns and special offers;
— handle your enquiries and requests.

UniSender processes personal data in accordance with applicable data protection law and takes the organisational and technical measures required to protect personal data against unlawful access, destruction, alteration, blocking, copying and distribution.

The UniSender privacy policy is available at: https://www.unisender.com/ru/privacy-notice/

You may unsubscribe from our newsletters at any time using the unsubscribe link included in every message, or by sending a request to our email address: info@proxy.market

Once you unsubscribe, your data will be removed from the UniSender mailing database within 3 (three) business days.

Sharing Data with Third Parties

In order to provide our services and improve their quality, we share information about you with the following third parties:

Data Security

The personal data we collect and store is treated as confidential information. It is protected against loss, alteration and unauthorised access in accordance with applicable data protection law. To achieve this, we apply technical means and organisational measures. We continuously improve our data protection systems.

Changes to This Policy

We reserve the right to amend this Policy at any time. We ask you to review any updates to the Policy regularly. Where such changes are material, we will notify you of them by every means available to us.

Contact Us

For any questions relating to the processing and protection of personal data, you can contact us by email at info@proxy.market