- 1. Terms and Definitions
1.1 Policy – this Privacy Policy and Cookie Policy published on the Website.
1.2 We, Us, Our, Operator, or Company – LLC “Innova” (TIN: 7720944020), info@prostoplati.com.
1.3 You, Your, Data Subject, or User – an individual using the Website and accepting the Public Offer under which this Policy applies.
1.4 Personal Data – any information relating to an identified or identifiable individual, including but not limited to name, surname, patronymic, ID number, location data, online identifiers, or factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity, as well as information received from third parties.
1.5 Personal Data Processing – any action (operation) or set of actions performed with or without automated means on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction. Processing is carried out in a mixed (including automated) manner.
1.6 Automated Processing – processing of personal data using computing technology.
1.7 Personal Data Confidentiality – the obligation of the Operator and other persons accessing personal data not to disclose it without the Data Subject’s consent or other legal grounds.
1.8 Anonymization – actions making it impossible to identify the personal data owner without additional information.
1.9 Website – https://prostoplati.com.
1.10 Cookies – small text files placed on your computer or device when you visit certain sections of the Website.
1.11 Federal Law No. 152-FZ – Federal Law of the Russian Federation “On Personal Data” dated July 27, 2006.
1.12 GDPR – General Data Protection Regulation 2016/679 of the European Parliament and Council dated April 27, 2016, on the protection of individuals regarding personal data processing and free movement of such data, replacing Directive 95/46/EC with amendments applicable within EU member states.
- 2. Subject and Legal Basis for Processing
2.1 This Policy governs the relationship between Us and You concerning the processing of personal data arising from your use of the Website and acceptance of the Public Offer (https://prostoplati.com/offer).
2.2 Your consent is the legal basis for processing your personal data. Without your consent to this Policy, we may not be able to fulfill contractual obligations properly.
- 3. Acceptance of the Policy
3.1 This section explains actions that signify your consent to the processing of your personal data (“Consent to Processing”).
3.2 By providing Consent to Processing, you confirm that you have read, understood, and agree with the Public Offer, its appendices, and this Policy, granting specific, informed, conscious, and unambiguous consent for processing your personal data.
3.3 Consent includes your agreement to automated and non-automated processing as outlined in this Policy.
3.4 Registration: ticking the checkbox during registration signifies your agreement with this Policy.
3.5 Browsing the Website implies your consent to processing the technical data and cookies specified in this Policy unless otherwise indicated on the Website.
3.6 Providing information voluntarily (e.g., emailing us) constitutes your consent to processing your data from the moment it is received, stored for the response and subsequent correspondence history, but not longer than one month.
3.7 Making a call to the Operator and continuing the conversation signifies your consent to processing.
3.8 Sending a message via messenger or Website chat signifies your consent to processing upon sending the first message.
3.9 We may store logs or other evidence of your consent for the duration of your account and up to 3 years after its deletion unless a different period is legally required.
- 4. Duration of the Policy and Data Processing
4.1 The Policy is effective indefinitely upon acceptance. However, this does not affect the processing period of your personal data, which is established by this Policy.
4.2 As a general rule, we process your personal data for as long as your Personal Account exists on the Website. If you have not registered, we process data until your inquiry is addressed and for 3 (three) years afterward, unless a different retention period is required by applicable law. We will stop processing your personal data if you object to such processing or withdraw your previously given consent, in accordance with this Policy and applicable law. However, this may prevent us from fulfilling contractual obligations to you.
4.3 Amendments. We may modify this Policy at any time, including due to changes in our business processes or external factors. Once amended, the updated Policy will be immediately published on the Website for your review. Continued use of the Website after amendments signifies your acceptance of the updated Policy.
- 5. Legal Grounds, Purposes, and Principles of Processing
5.1 Legal Grounds. This Policy has been developed in accordance with laws and regulations governing personal data processing, including Federal Law No. 152-FZ and GDPR.
5.2 Purposes. The Policy aims to: (1) ensure the protection of human and civil rights during personal data processing, including the right to privacy; (2) prevent unauthorized access to, destruction, modification, blocking, copying, and distribution of your personal data; (3) ensure confidentiality and control over your personal data; (4) protect constitutional rights to privacy and confidentiality, and prevent potential threats to your security. The primary purpose of this Policy is to provide you with a clear understanding of the legal basis for the collection and processing of your personal data, what categories of data we collect, how we process it, where it is processed, retention periods, data sharing practices, and your rights as a data subject.
5.3 Principles. We adhere to the following principles when processing personal data: (1) lawfulness and fairness; (2) purpose limitation, ensuring that data is processed only for specific, legitimate purposes; (3) data minimization, ensuring that the data collected is adequate and relevant; (4) accuracy and keeping data up to date; (5) storage limitation, ensuring that data is not kept longer than necessary unless required by law.
- 6. Types of Data Processed
6.1 Registration Data. During registration, we may request your username (please do not use your real name) and email address to fulfill our obligations under the contract (e.g., creating your Personal Account).
6.2 Technical Data. We automatically collect certain technical data when you use the Website, including IP address, system login information, browser type and version, time zone settings, browser plugin types and versions, operating system, platform, and visit information.
6.3 Additional Data. In rare cases, we may request additional personal data, informing you beforehand and obtaining your explicit consent for processing such additional data.
6.4 Third-Party Data. If you provide us with third-party personal data, you guarantee that you have obtained all necessary consents (including for data transfer) and that you comply with applicable laws in your jurisdiction. You are fully responsible for ensuring compliance with these guarantees.
- 7. User Rights
7.1 Right to Information. You have the right to receive information about us, our location, the availability of your personal data, and access to such personal data.
7.2 Right to Rectification. You have the right to request the correction, blocking, or deletion of your personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing.
7.3 Form of Provision. Information about the availability of your personal data will be provided in an accessible form and will not contain personal data related to other data subjects.
7.4 Content of the Response. In your request for access, you may request details regarding the processing of your personal data, including: (1) confirmation of processing and its purpose; (2) methods of processing; (3) the name and location of the Operator and data recipients; (4) a list of processed personal data and its source; (5) data processing and storage periods; (6) potential legal consequences of processing your personal data.
7.5 Right to Withdraw Consent. You have the right to withdraw your consent to the processing of your personal data, limit methods and forms of processing, and prohibit the distribution of your personal data without your consent.
7.6 Right to Appeal. You have the right to appeal our actions or inactions to the authorized data protection authority or in court.
7.7 Right to Protection. You have the right to protect your rights and lawful interests, including the right to claim damages and moral compensation in court.
7.8 Access Procedure. You (or your legal representative) may access your personal data by making a personal request or by sending a written request containing your identification details and signature. Requests may also be sent electronically. We will respond within 30 days of receiving your request, extendable to 60 days depending on complexity and volume.
- 8. Rights under GDPR
If you are a citizen of an EEA member state or the UK, or if you lawfully provide us with such data, you are entitled to the following rights under GDPR by contacting us via our contact details:
8.1 Right to be Informed (Articles 12-14 GDPR). You have the right to receive clear and transparent information about the collection and use of your personal data, including the purposes of processing, retention periods, and who it will be shared with, at the time of collection or within a reasonable period if collected from other sources.
8.2 Right of Access (Article 15 GDPR). You have the right to request confirmation of whether your personal data is being processed, and if so, access to that data and related information, including processing purposes, data categories, recipients, retention periods, rights to rectification or erasure, the right to lodge a complaint, and information on data transfers.
8.3 Right to Rectification (Article 16 GDPR). You have the right to request correction of inaccurate or incomplete personal data without undue delay.
8.4 Right to Erasure (“Right to be Forgotten”, Article 17 GDPR). You have the right to request the deletion of your personal data under specific conditions.
8.5 Right to Restrict Processing (Article 18 GDPR). You have the right to request the restriction or cessation of the processing of your personal data under specific conditions.
8.6 Right to Data Portability (Article 20 GDPR). You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller, where technically feasible.
8.7 Right to Object (Article 21 GDPR). You have the right to object at any time to the processing of your personal data on grounds relating to your situation, including profiling and direct marketing.
8.8 Rights Related to Automated Decision-Making and Profiling (Article 22 GDPR). You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you.
- 9. Data Transfer
9.1 Data Transfer. To achieve the purposes of personal data processing, we may need to provide your personal data to our partners and contractors. Your personal data may also be transferred to government authorities upon request in accordance with the law.
9.2 Mandatory and Optional Transfers. Data transfers may be mandatory, such as information about your device (IP address, OS, location data, device ID/type, browser/application used, payment authorization, identification/verification), or optional, such as matching address indicators, account information, and others.
- 10. Data Storage
10.1 Data Localization. If you are a citizen of the Russian Federation, we store your data on servers located within the territory of the Russian Federation. If you are a citizen of an EEA member state, the UK, or another country with applicable personal data legislation requiring local processing, your data will be collected and processed within the EEA or the relevant jurisdiction accordingly.
- 11. Data Protection Measures
11.1 Protection Principles. We apply legal, organizational, administrative, technical, and physical measures to protect your personal data.
11.2 Protection Measures. Measures to ensure the security of personal data during processing are planned and implemented to comply with legal requirements. Our protection measures include: (1) restricting and specifying staff with access to personal data; (2) appointing a data protection officer; (3) developing and implementing internal regulations on personal data processing; (4) identifying threats to personal data security in information systems; (5) applying organizational and technical measures to ensure security; (6) using certified information protection tools; (7) keeping records of electronic media; (8) establishing access rules to personal data; (9) restricting access to premises where processing equipment and media are located; (10) detecting and responding to unauthorized access; (11) including personal data in the Operator’s list of confidential information; (12) obtaining confidentiality agreements from employees processing personal data; (13) restoring personal data modified or destroyed due to unauthorized access; (14) educating employees on personal data laws and security requirements; (15) monitoring implemented personal data security measures.
- 12. Use of Cookies
12.1 Use of Cookies. The Website uses cookies. When visiting the Website, your browser sends certain information to our server: (1) date and time of visit; (2) browser type; (3) language settings; (4) operating system. This information is stored in connection logs for a limited time (session to one year) for security, functionality, and statistics purposes.
12.2 Types of Cookies. Functional and technical cookies enable the Website to recognize your session, language, and browser to ensure full functionality. These cookies help personalize the Website and remember your preferences. Analytical cookies help us understand visitor counts and navigation patterns to improve the Website. You may disable analytical cookies through your browser settings.
12.3 Cookie Storage Duration. Cookies may be “Session Cookies” (stored until the browser is closed) or “Persistent Cookies” (stored until their expiration date or deletion by you).
12.4 Cookie Management. You can manage cookie preferences via your browser settings. Note that disabling cookies may limit the functionality of the Website. For more information, visit www.aboutcookies.org or www.allaboutcookies.org.
- 13. Contact for Legal Correspondence
13.1 Contact Information. Legal communication within this Policy and any related obligations will be conducted via official contact channels in writing or electronically, with electronic communication being equivalent to paper-based. Our email for personal data inquiries: info@prostoplati.com.
- 14. Final Provisions
14.1 Severability. If any part of this Policy is deemed invalid, the remaining parts will remain in effect, and the Policy shall not be deemed invalid in full under any circumstances.