Policy on personal data processing

1. General provisions

This policy of personal data processing is drawn up in accordance with the requirements of the Federal Law dated 27.07.2006. No. 152-FZ “On Personal Data” and defines the procedure of personal data processing and measures to ensure personal data security taken by 1Win (hereinafter referred to as the Operator).
1.1 The Operator sets as its most important goal and condition of its activity the observance of human and citizen’s rights and freedoms during the processing of personal data, including the protection of rights to privacy, personal and family secrecy.
1.2 This Operator’s policy on personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about the visitors of the website https://app1.win/.

2. Basic concepts used in the Policy

2.1 Automated processing of personal data – processing of personal data by means of computer equipment;
2.2 Blocking of personal data – temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data);
2.3. Website – a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://app1.win/;
2.4 Personal data information system – a set of personal data contained in databases and information technologies and technical means ensuring their processing;
2.5. Personal data depersonalization – actions, as a result of which it is impossible to determine without using additional information whether personal data belong to a particular User or other subject of personal data;
2.6 Processing of personal data – any action (operation) or set of actions (operations) performed with the use of automation means or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
2.7. Operator – a state authority, municipal authority, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data;
2.8 Personal data – any information relating directly or indirectly to a certain or defined User of https://app1.win/ website. 2.9. User – any visitor of https://app1.win/ website;
2.9. User – any visitor of the website https://app1.win/;
2.10. Provision of personal data – any actions aimed at disclosure of personal data to a certain person or a certain circle of persons;
2.11. Dissemination of personal data – any actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or familiarization of personal data to an unlimited number of persons, including disclosure of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way;
2.12. Trans-border transfer of personal data – transfer of personal data to the territory of a foreign country to a foreign government authority, foreign individual or foreign legal entity;
2.13. Destruction of personal data – any actions as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of personal data content in the personal data information system and (or) material carriers of personal data are destroyed.

3 The Operator may process the following personal data of the User

3.1 Surname, first name, patronymic;
3.2. e-mail address;
3.3. Telephone numbers;
3.4 The website also collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrica and Google Analytics, etc.).
3.5 The above mentioned data are hereinafter referred to in the text of the Policy as Personal Data.

4. Purposes of Personal Data Processing

4.1 The purpose of processing the User’s personal data is to inform the User by sending e-mails; to provide the User with access to services, information and/or materials contained on the website.
4.2 The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending a letter to the Operator to the e-mail address [email protected] with the note “Refusal of notifications about new products and services and special offers”.
4.3 The User’s anonymized data collected through Internet statistics services are used to collect information about the User’s actions on the website, to improve the quality of the website and its content.

5. Legal basis of personal data processing

5.1 The Operator processes the User’s personal data only if it is filled in and/or sent by the User himself/herself through special forms located on the website https://app1.win/. By filling in the relevant forms and/or sending his/her personal data to the Operator, the User expresses his/her consent to this Policy.
5.2 The Operator processes anonymized data about the User if it is allowed in the User’s browser settings (cookies and JavaScript technology enabled).

6. Procedure for collection, storage, transfer and other types of personal data processing

The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary for full compliance with the requirements of the current legislation in the field of personal data protection.
6.1 The Operator shall ensure safety of personal data and take all possible measures to exclude access to personal data by unauthorized persons.
6.2 The User’s personal data will never, under no circumstances, be transferred to third parties, except for cases related to the execution of the current legislation.
6.3 In case of identifying inaccuracies in personal data, the User may update them independently by sending a notice to the Operator to the Operator’s e-mail address [email protected] with the note “Personal Data Update”.
6.4 The period of personal data processing is unlimited. The User may withdraw his/her consent to the processing of personal data at any time by sending a notice to the Operator by e-mail to the Operator’s e-mail address [email protected] with the note “Withdrawal of consent to the processing of personal data”.

7. Cross-border transfer of personal data

7.1 Before commencing the trans-border transfer of personal data, the Operator is obliged to make sure that the foreign state, to the territory of which the transfer of personal data is to be carried out, ensures reliable protection of the rights of personal data subjects.
7.2 Trans-border transfer of personal data to the territory of foreign states, which do not meet the above requirements, may be carried out only if the personal data subject consents in writing to the trans-border transfer of his/her personal data and/or fulfillment of the agreement to which the personal data subject is a party.

8. Final provisions

8.1. The User may obtain any clarifications on issues of interest regarding the processing of his/her personal data by contacting the Operator via e-mail at [email protected].
8.2. This document will reflect any changes in the policy of personal data processing by the Operator. The Policy is valid indefinitely until it is replaced by a new version.
8.3. The current version of the Policy is freely available on the Internet at https://app1.win/.