1.Introduction

 

Znanie Development Company Ltd and all its affiliates and/or subsidiaries (also referred to as we, us, our) are committed to protecting the privacy and security of individuals (also referred to as you, users, visitors) according to European Union (the “EU”) and international law.  

We ensure protection of your personal data by applying high standards of conduct for privacy issues. We also ensure that our employees are provided with the appropriate training to handle personal data in accordance with the applicable laws. 

 

This privacy policy (“Privacy Policy”) explains how we control and/or process personal data in connection with our website: “thequestion.ru”, “thequestion.com”, “thequestion.pro” (the “Website”) or any mobile application software. This policy sets out the basis on which any personal data we collect, or that you provide to us, will be processed from us. It also describes the rights you have and control you can exercise in relation to it. 

Please read this Privacy Policy in conjunction with our Terms of Use.

 

2. Personal data

 

For the purpose of this Privacy Policy we are the data controller.  The term ‘personal data’ used in this Privacy Policy applies to any information about you which can be used to personally identify you, such as your name, address, telephone number, e-mail address, or any other personal information you might supply. 

 

Keeping users’ information safe and secure is among our highest priorities. Data protection laws vary by country and those applicable in the USA and elsewhere are not equivalent to those applicable in, for example, the EU or certain other jurisdictions. We will, take steps to protect your information in line with locally applicable data protection requirements.  For the EU citizens, for example, we spent time and resources working closely with EU data protection specialists, and we have already implemented privacy protection mechanisms that reflect the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 scope. 

 

Please read the following carefully to understand our views and practices regarding your personal data and how we treat it, prior to accessing or utilizing the Website information. 

 

3. What kind of personal information about you do we process?

 

Information you give us:

  • Contact information: You may give us information about you by filling in forms on our Service or by corresponding with us by e-mail or otherwise. This includes information you provide when you register to use our Service, subscribe to our Service, participate in discussion boards or other social media functions on our Service and when you report a problem with our Service. The information you give us may include, but not be limited to, your name, postal address, e-mail address, phone number (including mobile phone number where provided), personal description and photograph; 

* We do not knowingly collect personally identifiable information from anyone under 16 years old. If you are under 16 years old, you may not submit any personal data to us.  If you are a parent or guardian and you are aware that your children has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from us.

 

  • Supplier data: contact details and other information about you or your company or organization where you provide services to us

 

Information we collect about you:

With regard to each of your use of our Service (including visits to our Website) we may automatically collect the following information:

  • Your login ID and password: for access to our Direct, extranets and other client services or platforms;
  • Information from public sources: e.g. Linked in and similar professional networks, directories or internet publications;
  • Subscriptions/preferences: when you subscribe to receive updates or newsletters as well as consent preferences to help us identify which materials you are interested in receiving;
  • Events data: attendance at and provision of feedback forms in relation to our events;
  • Social media: posts, Likes, tweets and other interactions with our social media presence;
  • Technical information: when you access this Website and our technology services being IP address, browser type and version (e.g. Internet Explorer, Firefox, Safari etc.), time zone setting, browser plug−in types and versions, operating system you are using (e.g. Vista, Windows XP, MacOS, etc), device type, hardware model, MAC address, unique identifiers and mobile network information;
  • Online data: when you access this Website and our technology services, information about your visit including Uniform Resource Locators (URL)  clickstream to, through and from our Website (including date and time), information about your network as such as information about devices, nodes, configurations, connection speeds and network application performance; pages viewed or searched for, page response times, download errors, length of visits and interaction information (such as scrolling, clicks, mouse-overs) and whether you click on particular links or open our emails   

 

Cookies:

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. The personal data we collect through these technologies will also be used to manage your session.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.

For more information about cookies and how we use them, please see our: Cookies Notice

 

4. Our reasons for using your personal data

 

We will process your personal data for a number of reasons:

  • to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to maintain back-ups of our databases and communicate with you;
  • to improve our Service to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our Service, when you choose to do so;
  • as part of our efforts to keep our Service safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; 
  • to make suggestions and recommendations to you and other users of our Service about services that may interest you or them;
  • to understand topics of interest, market demand and trends, website usage and engagement, visitor profiles e.g. geographical;
  • to improve our Website design and content;
  • to improve our products and services;
  • to market our products/services better including marketing communications and search engine optimization; 
  • to respond to any feedback; and
  • to send emails, newsletters and other messages to keep you informed of legal developments, market insights and of our services

 

5. With whom do we share your data?

 

  • Suppliers: who support our business including IT and communication suppliers and outsourced business support. Our suppliers have to meet minimum standards as to information security and they will only be provided data in line with their function;
  • Our employees who are acquainted with the applicable laws;
  • Shared service centers: operated by us or third parties including IT services, marketing, risk management and office support services;
  • Law enforcement bodies and our regulators: or other competent authorities in accordance with legal requirements or good practice;
  • Appropriate parties in the event of emergencies: in particular to protect safety of our clients, staff and organizations;
  • Advertising networks and analytics service providers: to support and display ads on our Website, apps and other social media tools;
  • Third parties: in the context of the acquisition or transfer of any part of our business or in connection with the business reorganizations such us: 
  • acquisitions and transfers of our business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • if our company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; 
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use; or to protect the rights, property, or safety of us, our customers or others as provided in question 6 below;
  • to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries from time to time and
  • other third parties including:
  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them;
  • advertisers and advertising networks that require the data to select and serve relevant adverts to you and others; and
  • analytics and search engine providers that assist us in the improvement and optimization of our Website.

 

  • Other delegates: where your name will appear on the attendee list for events where you have told us you plan to attend.

 

6. What are the legal grounds for our processing of your personal information? 

 

We may share information (including personal information) if: 

  • you have given us consent: for example where you share details for particular purposes;
  • this is necessary to comply with legal or regulatory obligations: for example anti-money laundering and mandatory client screening checks;
  • we have a legal obligation to do so, and/or when we have a good faith/ belief that such action is necessary to comply with either a court order; legal process served on us and/or a court order. 
  • processing is necessary for our legitimate business interests or those of a third party:  provided this does not override any interests or rights that you have as an individual. Our legitimate interests are listed in the next section.

 

 

7. Legitimate interests

 

We have legitimate business interests in:

 

  • managing our business and relationship with you or your company or organization;
  • understanding and responding to inquiries and client feedback;
  • understanding how our clients use our services and Websites;
  • identifying what our clients want and developing our relationship with you, your company or organization;
  • improving our services and offerings; 
  • enforcing our terms of engagement and Website and other terms and conditions;
  • ensuring our systems and premises are secure;
  • ensuring debts are paid;
  • operating suppressors to exclude you from direct marketing if you unsubscribe;  
  • sharing your data in connection with acquisitions and transfers of our business;
  • any other purpose(s) which has been agreed by or notified to you.

 

 

8. Security of your Personal Data.

 

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

 

We have implemented administrative, technical, and physical measures designed to protect your personal information from accidental loss and from unauthorized access, disclosure, use, alteration, or destruction. These measures include computer safeguards and secured files and buildings, Internet firewalls, intrusion detection, anti-virus protection, network monitoring, or encrypted browsers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Service; any transmission is at your own risk. Once we have received your information, we will use reasonable measures and security features to try to prevent unauthorized access.

 

If a password is used to help protect your accounts and personal information, it is your responsibility to keep your password confidential. Please also be careful to avoid “phishing” scams, where someone may send you an email that looks like it is from us asking for your personal information. We will never request your personal information through e-mail. 

 

9. How long your data is kept 

 

We keep the data for the time necessary to fulfill the purpose of processing of your services or requests. 

 

10. Right to Access and Control Your Personal Data

 

If you are within the jurisdiction of one of the EU Member States or in certain other jurisdictions where similarly rules apply, you have certain rights in relation to your information. The availability of these rights and the ways in which you can use them are set out below in more detail.

 

Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact the relevant Data Privacy contact as listed in this Policy above.

 

  • Access: you are entitled to ask us if we are processing your data and, if we are, you can request access to your personal data.  This enables you to receive a copy of the personal data we hold about you and certain other information about it;
  • Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected;
  • Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims;
  • Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
  • Transfer: you may us to help you request the transfer certain of your personal data to another party;
  • Objection: where we are processing your personal data based on a legitimate interests (or those of a third party) and you may challenge this.  However, we may be entitled to continue processing your information. You also have the right to object where we are processing your personal information for direct marketing purposes;
  • Automated decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.
  • Consent: where we are processing personal data with consent, you can withdraw your consent.

 

If you want to exercise any of these rights, please contact one of the Data Privacy contacts set out in this Policy above, in writing at the relevant email address.

 

You also have a right to lodge a complaint with a data protection supervisory authority, in particular in the Member State in the European Union where you are habitually resident where we are based or where an alleged infringement of Data Protection law has taken place. In the UK you can make a complaint to the Information Commissioner's Office (Tel: +357 22 818456 or at www.dataprotection.gov.cy). 

 

11. Right to object

 

If you are working with one of our EU legal practices or our practices in certain other jurisdictions where similar rules apply, you may have a right to object to us processing your information in certain circumstances. This applies where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this.  However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims.  You also have the right to object where we are processing your personal information for direct marketing purposes. 

 

12. Direct Marketing 

 

As described above, you can opt-out of receiving direct marketing from us at any time.

We may use the information you give us on our Website or other means for direct marketing purposes to provide emails, newsletters and other messages to keep you informed of legal developments, market insights and of our services including events that we think may interest you.

You can opt-out of receiving direct marketing from us at any time.  You can do this by changing your marketing preferences on your online accounts settings page, clicking on the "unsubscribe" link included at the end of any marketing email we send to you.

 

13. External links

 

Our Service may, from time to time, contain links to and from the websites of partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

 

14. Changes to this Privacy Policy 

 

We may update this Privacy Policy periodically, and will note the date of its most recent revision above. If we make material changes to this Privacy Policy, we will notify you by prominently posting a notice of such changes prior to implementing the changes.

 We encourage you to review this Privacy Policy frequently to be informed of how we are using, protecting, collecting, retaining, disclosing, and transferring your information. 

 

15. Contacting us

 

Questions, comments and requests regarding this Privacy Policy should be addressed to support@thequestion.ru.

 

This Privacy Notice was last updated on 22 August, 2018. 

 

 

Вернуться наверх