PRIVACY POLICY

This version of the Privacy Policy came into force on 23.05.2022

This Privacy Policy (hereinafter referred to as the “Policy”) describes how Axlebolt LTD (hereinafter referred to as “Axlebolt”, “we” and derivatives) and its subsidiaries and affiliated companies process personal data as part of providing access to services on the site axlebolt.com (hereinafter referred to as the “Site”). By using our Site and/or agreeing to the Policy by filling out the relevant forms on the Site, you or your legal representative (hereinafter referred to as the “User”) accept this Policy.

If you are an underage person, please ask your parents (legal representative) to read this Policy. For an underage person, the Policy is accepted by his legal representative. If you are an underage person and you are unable to present this Policy to your legal representative, or if you or your legal representative does not agree with the terms of this Policy, please stop using the Site immediately.

If a legal representative allows an underage person to use the Site, we presume that the legal representative has read and accepted the Policy on behalf of the underage person.

At the same time, we do not purposefully collect personal data from Users under 18 since the Site is intended for a general audience and is targeted at a wide range of individuals with full legal capacity.

The Policy on axlebolt.com is the most current version. We may update this Policy unilaterally over time, in order, inert alia, to comply with recent changes in applicable legislation and law enforcement. All changes are effective when posted on this page. Please review the latest version of this Privacy Policy on the Site from time to time.

1.         WHAT DATA DO WE COLLECT AND PROCESS?

We process the following information related to Users:

- Contact and personal information (if a User submits their CV for consideration for our openings);

- Cookies: Technical, sessional and analytical.

We try to minimize the collection of personal data and do not collect additional information about you.

In order to process User’s data, we obtain consent in accordance with the Policy. Users have the option to withdraw their consent at any time or to request the deletion of any information we have collected, but in this case, we will be forced to restrict access to certain features of the Site, including access to the Personal Account. 

In addition to User’s consent, we rely on our legitimate interest as the legal basis for data processing.  

2.         ON WHAT BASIS AND WHAT FOR DO WE PROCESS THIS DATA?

Below you can find the legal basis and purpose for collecting the personal data listed in Section 1 of this Policy:

Category of data

 

Legal basis

 

Characteristics of data and purpose(s) of processing

 

Contact information

 

Your consent (including those which expressed in conclusory acts)

 

You can provide us with your contact information by filling out a request form on the Site to receive feedback and/or updates from us. We may use your email address (or whichever communication method you have chosen as your primary means of contact) to contact you regarding various matters. In addition, you may provide us with your other contact information of your choice, as described below.

 

Personal information

 

Your consent (including those which expressed in conclusory acts)

 

This type of data may contain personal information that identifies you personally. Using the Site, you can send us (by attaching or sending your CV through the Site or by email) your CV for employment, which may contain the following information: Your first name, surname, gender, age, ethnicity, photo image, place of residence, hobbies, links to social media accounts, education, work experience, phone number, zip code, mailing address, other contact information, and other personal information you may put on your resume. When you send us your CV, it is up to you to determine the specific amount of your personal information that we collect and process.

 

Analytical, sessional and technical Cookies

 

·                Consent (including expressed in conclusory acts)

·                Our legitimate interest in obtaining static data for market analysis and research and improvement the quality of services and the Site

 

Cookies are small text files that are stored on your device during your visit a website. We use cookies to anonymously analyze use of the Site, as well as to provide you with additional features on the website, facilitate your interaction with the Site and ensure error-free use (for example, to make it easier to navigate the Site or to save your preferences and settings for your next visit).

 

 

3.         FOR WHAT PURPOSES DO WE PROCESS PERSONAL DATA?

We process your data in order to provide information services related to the Site and its functions, as well as to review CV you have provided. At the same time, we use your data to contact you as necessary.

We DO NOT process your personal data to sell it.

We also process your personal data where we have a duty to do so under applicable law.

4.         TO WHOM PERSONAL DATA MAY BE TRANSFERRED

By agreeing to this Policy, you comfirm that you consent to the transfer of your data pointed in this Policy to our affiliates and partners that are not affiliated with us.

We do guarantee that agreements entered into with third parties provide a level of protection no lower than that provided for in this Policy, which complies with the requirements of Russian legislation on personal data.

Transfer for commercial purposes

In order to provide you with the best possible user experience and to comply with the terms of the User Agreement between you and us, we may share your personal data with third parties.

We transfer data to third parties for only the following purposes:

1) Improving the quality of the Site and services provided, market research

We allow third-party services to collect your data so that we can provide services to our Users, measure, analyze and improve Site performance, and continuously update and improve our Site and services.

We may use this information to correct any errors on the Site, evaluate our User demographics data and determine whether new device types need to be supported for the Site, and determine whether changes to our marketing and distribution solutions are necessary.

Cookies may be provided and used by us to learn more about our audience and the effectiveness of the measures we use to attract interest in our Site and the services on it, the viability of the services as business projects.

In this regard, the following categories of personal data may be shared with partners:

- Analytical, sessional and technical Cookies.

The listed data are transferred to the following third parties:

YANDEX, LLC (TIN 7736207543, PSRN 1027700229193). Here you can read the privacy policy of Yandex LLC

Google, Inc. (1600 Amphitheatre Parkway, Mountain View, California, 94043, США. Here you can read the privacy policy of Google LLC

 

The information collected by Cookie cannot identify you, but it can help us improve our Site.

2) Transfer by virtue of law

We may disclose information that you provide in order to respond to subpoenas, requests, notices, court orders, requests from public authorities in any proceeding, and to establish / exercise our rights.

We may also disclose your information to protect from legal claims if we believe that disclosure is necessary to protect our rights, your safety or the safety of others, to investigate fraud, or to respond to a government request.

We may transfer your information in order to investigate, prevent or take action regarding illegal activities, suspected fraud and situations involving potential threats to the physical safety of any person, or as otherwise required by law.

5.         CAN WE RECEIVE PERSONAL DATA FROM THIRD PARTIES?

At the present time the functionality and mechanisms of the Site do not involve the receipt of personal data from third parties.

6.         HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will process your personal data for as long as you continue to use the Site. If you stop using the Site, as a general rule, we will continue to process your personal data for the next 2 years so that you can resume using the Site and we can use the data for analytical purposes. After that period, we will delete your personal data. We may also delete your personal data earlier than the determined period in case we no longer need it.

Please note that a different processing period may be stipulated for Cookies.

7.         IS USER DATA IN SECURE?

The security of your personal data is important to us.

We follow generally accepted standards to protect your information both during transferring and after it is received. However, no method of transfer over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee absolute security.

While no security system is completely secure, we and our partners take appropriate security measures to protect against unauthorized access or disclosure of the information we collect. For Axlebolt, this includes, among other things:

 

·      preventing disclosure of your data unless necessary

·      ensuring that all information collected by Axlebolt is transferred over secure connections,

·      protection and encryption by software with the appropriate level to protect against unauthorized access.

 

Our employees and third parties who access your data are obliged to keep your data confidential.

8.         WHAT RIGHTS DOES THE USER HAVE WITH RESPECT TO HIS OR HER DATA?

Each User has the right to:

·      Obtain information about the personal data we process. If you choose to exercise your right, we will provide you with information about the processed personal data within 30 calendar days as of receiving your request. Please note that we will not consider a similar request for information about processed personal data if you make a second request within 30 calendar days as of your first request;

·      Clarify processed personal data if such data is defective, incomplete, outdated or inaccurate in any way. If your request proves to be justified, we will take appropriate action within seven business days as of receiving such a request;

·      Block personal data. This right means that you may request a temporary suspension of data processing by us;

·      Request the remove of personal data. If your request is justified, we will delete your personal data within seven business days as of receiving such a request if there is no other legal basis for processing; and

·      Take statutory steps to protect your data, for example, you may file a complaint with Roskomnadzor if you believe that we are processing your data in violation of the law.

If you wish to exercise any of your rights, please contact us at privacy@axlebolt.com. You can also send us a written request to 422110, The Republic of Tatarstan, Kukmorskiy district, Kukmor city, Lenina Street, house 24, apartment 2, room 43.

Please note that we may require additional information to identify the person making the request in order to grant the request. If providing the information may violate the rights and legitimate interests of third parties, we may refuse to provide you the information.

In order to exercise the rights outlined above, your request must include the following information:

1)     the number of the main document certifying your identity or the identity of your representative;

2)     information about the date of issue of the document and the issuing authority;

3)     information confirming your participation in a relationship with us or information otherwise confirming that we process personal data by us; and

4)     your or representative's signature.

Taking into account the requirements of current legislation of the Russian Federation, we hereby ask you to send us requests in the form of scanned copies signed with your handwritten signature.

9.         IS MY PERSONAL DATA BEING TRANSFERRED ABROAD?

Axlebolt may transfer personal data outside the Russian Federation for the purposes set forth in this Policy.

Cross-border transfer of personal data is restricted by 152-FZ with respect to countries that cannot provide the same level of data protection as the legislation of Russia, except in cases where such a transfer is made to fulfill a contract with the data subject or with his written consent. In our case, the transfer of data is carried out to our partners only in those countries that can provide the same level of data protection as the legislation of Russia.

We also want to assure you that your data is secure and our partners adhere to high standards of data protection, just as we do. We are committed to transfer your personal data abroad only using all necessary security mechanisms to protect your data, including data encryption.

10.       WHERE IS MY PERSONAL DATA BEING STORED?

We strongly guarantee that the personal data we collect are stored and updated on servers located in Russia in accordance with the requirements of the Law of the Russian Federation No. 152-FZ "On Personal Data".

Thank you for choosing our services!

Sincerely yours,
Axlebolt team