This Privacy Policy (“Policy”) covers any information, about you that may include personal data as defined by applicable laws and regulations (“Personal information”), which OptiSystems LLC or affiliated entities, including all entities belonging to the same group as OptiSystems LLC (“OptiSystems”), may obtain when you use any of the OptiSystems websites, programs, products or services.
To provide you with access to the Sites and Services, your Personal information is collected and used by OptiSystems LLC, a company incorporated under the Russian law, with a head office registered at 25 Yunih Lenintsev St., Moscow 109462, Russia (“OptiSystems” LLC), or its affiliates for particular Services.
Privacy and security of your Personal information are extremely important to us. When you use the Sites and/or Services, OptiSystems processes your Personal information and ensures its protection in strict compliance with applicable laws and regulations.
As part of our commitment to protecting your Personal information, we use this Policy to transparently inform you about the following:
(a) why and how your Personal information is used (also, “processed”) by OptiSystems when you access the Sites or Services;
(b) OptiSystems’s role and responsibilities in this context as the legal entity deciding why and how your Personal information is processed;
(c) what instruments you may use to limit the amount of Personal information collected by OptiSystems; and
(d) what your rights are in relation to the above processing.
Personal information collected when you use the Sites and/or Services may differ depending on whether you access the Sites or Services while logged in to your OptiSystems WFM user account or without logging in. When you are logged in to your OptiSystems WFM user account as you are using the Sites or Services, Personal information collected by OptiSystems may be collated and combined with other Personal information (such as your identity, contact details, age and gender, if you shared this information with us) collected by OptiSystems in your user account. OptiSystems does not verify Personal information provided by you and cannot posit if it is true and whether you have the legal capacity required. However, OptiSystems assumes that the information you provide is true, sufficiently complete and up-to-date.
Personal information collected by OptiSystems when you access, interact with or operate the Sites and/or Services includes:
(i) information provided by you when you register (create) a user account, such as your name, mobile phone number, address and age;
(ii) electronic data (http headers, IP address, cookies, web beacons/pixel tags, browser information, information about your hardware and software);
(iii) date and time of accessing the Sites or Services;
(iv) information related to your activity when using the Sites or Services (e.g. your search history, email addresses of your contacts, content of your emails together with attachments, as well as files stored in OptiSystems systems);
(v) (geo)location information;
(vi) other information about you that needs to be processed according to the terms and conditions of any specific OptiSystems Site or Service; and
(vii) information about you that we may receive from our Partner in accordance with an agreement you made with this Partner and an agreement between OptiSystems and this Partner.
In addition, OptiSystems uses cookies to collect your Personal information and associate this Personal information with your device and web browser (see Section 11 below).
We do not perform any form of profiling which has the potential to significantly impact your rights and freedoms.
OptiSystems is not allowed to process your Personal information if it does not have a valid legal ground.
In most cases, Personal information is processed automatically without access to it by our staff. However, if such access is necessary, your Personal information can be accessed only by those OptiSystems employees whose professional tasks require using this information. To protect your Personal information and ensure its confidentiality, these employees must comply with internal rules and follow protocols for processing Personal information. They are also required to follow all technical and organisational security measures protecting your Personal information.
OptiSystems has also implemented adequate technical and organisational measures to protect Personal information against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of Personal information.
OptiSystems stores Personal information in the Russian Federation.
For users in Russia: OptiSystems records, systematizes, accumulates, stores, clarification (updates, changes), extracts Personal information of the citizens of the Russian Federation using databases located on the territory of the Russian Federation.
OptiSystems will only keep your Personal information for as long as it is necessary to fulfil the purpose for which it was collected or to comply with legal and regulatory requirements.
Unless otherwise legally required or agreed, the emails and documents, which are stored by you on our systems as part of the Service, will remain stored as long as you have an account with us, but you can delete them at any time.
If you wish to have any Personal information removed from our databases, you can have it removed via your OptiSystems WFM account or using interface of the Sites or Services (where applicable).
10.1 What are your rights
If it is provided by applicable law, you have a right of access to your Personal information as processed by OptiSystems under this Policy.
If you believe that any information we hold about you is incorrect or incomplete, you can log in to your user account and correct your Personal information yourself.
If it is provided by applicable law, you also have the right to:
OptiSystems will honour any such requests or objections as required under applicable law.
To the extent provided by applicable law, you may be subject to other rights not specifically mentioned herein.
10.2 How can you exercise your rights
To exercise the above rights, please log in to your user account, which will provide you with the option to do so, or in case of absence of special function in user account interface please contact OptiSystems (see Section 13 hereof).
If you are not satisfied with how OptiSystems processes your Personal information, please let us know and we will investigate your concern. If you are not satisfied with OptiSystems’s response, you have the right to make a complaint to the competent data protection authority.
11.1 What are cookies and what does OptiSystems use them for
Cookies are small text files placed on the device you use to access our Sites. They contain information that is collected from your device and sent back to the Sites on each subsequent visit so as to remember your actions and preferences over time.
The following types of cookies are used on the Sites:
11.2 How long are those cookies stored on your device
OptiSystems only uses the information contained in the cookies for the above purposes, after which the data collected will remain stored on your device for a period that may depend on cookies type, but no longer than necessary to achieve their purpose and will be automatically removed from your system thereafter.
11.3 Who else has access to the information contained in the cookies
Personal information collected through cookies placed on your device may be transmitted to and accessed by OptiSystems.
The first time that you access the Sites, your approval for the use of these cookies may be requested. If after you have approved the use of cookies you want to make another choice, you can do this by deleting the cookies stored by your browser (usually via the options in your browser’s Privacy menu – please refer to your browser’s manual or developer’s website). The popup requesting your approval may then show up again and you can make a different choice. If you do not consent to the use of cookies, certain features of the Sites might become unavailable, which may affect your browsing experience. You may also set up your browser preferences to accept or decline by default all cookies or cookies from specific websites, including the OptiSystems Sites. If you approved the use of cookies on one of the OptiSystems Sites, we assume that the use of cookies on all Sites was approved by you.
This Policy may be subject to amendments. OptiSystems shall be entitled to make such amendments at its own discretion, including, without limitation, to reflect changes in applicable legislation or amendments to the Sites and/or Services.
OptiSystems undertakes not to introduce significant changes, imposing additional obligations or reducing your rights under this Policy without proper notice to you. You will be notified about such changes. If applicable, changes will be announced on the Site (e.g. via a pop-up or web banner) prior to such changes taking effect, and you may also be notified via other channels (e.g. by email) if you have provided us with your contact details.