Personal Information Processing Policy

1. General Provisions

This Personal Information Processing Policy is based on the requirements of Federal Law No. 152-FZ "On Personal Information" from July 27, 2006 (hereinafter referred to as the Personal Information Protection Law). This Policy determines the personal information processing procedure and measures taken by Clever Machines LLC (hereinafter referred to as the Body Corporate) to ensure personal information security.

1.1. The most important goal and condition for the implementation of the Body Corporate’s activities is the observance of the rights and freedoms of persons and citizens regarding the processing of their personal information, including the protection of the rights to privacy, personal and family secrets.

1.2. This Body Corporate's Policy regarding personal information processing (hereinafter referred to as the Policy) applies to all information that the Body Corporate may receive about visitors of the https://clever-corp.com/ website.

2. Basic concepts used in the Policy

2.1. Automated processing of the personal information means the processing of personal information via computers and computer software.

2.2. Suspension of personal information means a temporary suspension of processing the personal information (unless such processing is required to clarify personal information).

2.3. Website means the aggregated graphic and informational content, as well as software and informationbases ensuring the availability of such content on the Internet at the network address of https://clever-corp.com/.

2.4. Personal information management system means the aggregated personal information contained in informationbases, as well as software, and hardware ensuring the processing of such information.

2.5. Anonymization of personal information means the actions which ensure the impossibility to identify the ownership of personal information by a specific User or other subject of personal information without the use of additional information.

2.6. Processing of personal information means any action (operation) or a set of actions (operations) performed with personal information with or without the use of automation tools including the collection, recording, categorization, accumulation, storage, revising (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, suspension, deletion, destruction of personal information.

2.7. Body Corporate means a state body, municipal body, legal entity, or individual administrating and (or) performing personal information processing independently or jointly with other parties, as well as determining the purposes of personal information processing, the composition of personal information to be processed, and actions (operations) to be performed with personal information.

2.8. Personal information mean any information related explicitly or implicitly to a specific or identifiable User of the https://clever-corp.com/ website.

2.9. Personal information authorized for distribution by the personal information subject — personal information, access to which is provided by the personal information subject to an unlimited number of parties by giving consent to the processing of personal information authorized by the subject of personal information for distribution in the manner specified in the Law on Personal Information (hereinafter referred to as personal information authorized for distribution).

2.10. User — any visitor to the https://clever-corp.com/ website.

2.11. Provision of personal information means actions aimed at the disclosure of personal information to a certain party or a certain number of parties.

2.12. Distribution of personal information means any actions aimed at the disclosure of personal information to any number of unspecified persons (transfer of personal information) or review of personal information by an unlimited number of parties, including the disclosure of personal information in the media, publication in information and telecommunication networks or providing access to personal information in any other way.

2.13. Cross-border transfer of personal information means the transfer of personal information to an authority in the territory of a foreign state, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal information means any actions leading to irreversible destruction of personal information with the impossibility of further restoration of its content in the personal information management system and (or) destruction of physical storage media containing personal information.

3. Basic rights and obligations of the Body Corporate

3.1. The Body Corporate has the following rights:

receive reliable information and (or) documents containing personal information from the personal information subject;
in case the personal information subject withdraws consent to the processing of personal information, the Body Corporate has the right to continue processing personal information without the personal information subject’s consent given such processing is permitted by the Information Protection Law;
independently determine the composition and set of measures required and sufficient to fulfill the obligations as per the Information Protection Law and the regulatory acts adopted in accordance with the Information Protection Law unless otherwise stated in the Information Protection Law or other federal laws.

3.2. The Body Corporate is obliged:

at the subject’s request, to provide the personal information subject with information regarding the processing of the subject’s personal information;
to arrange personal information processing in the manner required by the current legislation of the Russian Federation;
to respond to appeals and requests from personal information subjects and their legal representatives as per the requirements of the Information Protection Law;
at request, to report the required information to the body authorized in the protection of the rights of personal information subjects within 30 days from the date of receipt such a request;
to publish or otherwise provide unrestricted access to this Policy regarding the personal information processing;
to take legal, administrative, and technical measures to protect personal information from unauthorized or accidental access to personal information, as well as destruction, modification, suspension, copying, provision, distribution of personal information, and from other illegal actions related to personal information;
to stop the transfer (distribution, provision, access) of personal information, stop processing, and destroy personal information in cases and in manner as required by the Information Protection Law;
to perform other duties required by the Information Protection Law.

4. Basic rights and obligations of personal information subjects

4.1. Personal information subjects are entitled:

to receive information regarding the processing of their personal information except for the cases specified in federal laws. The Body Corporate shall provide the information to the personal information subject in a clear way. Such information shall not contain personal information related to other personal information subjects unless certain legal grounds exist for disclosing such personal information. The list of information and the procedure for obtaining such information is established by the Information Protection Law;
to demand from the Body Corporate to revise, suspend or destroy their personal information if the it is incomplete, outdated, inaccurate, illegally obtained or not required for the stated processing purpose, as well as to take legal measures to protect their rights;
to propose the term of prior consent for personal information processing in order to promote goods, works and services on the market;
to withdraw the consent to the processing of personal information;
to appeal to the authorized body for the protection of the rights of personal information subjects or contest in court against illegal actions or inaction of the Body Corporate when processing their personal information;
to exercise other rights stipulated by the legislation of the Russian Federation.

4.2. Personal information subjects shall:

provide the Body Corporate with reliable information about them;
notify the Body Corporate in the case of clarification (update, modification) of their personal information.

4.3. Persons who have provided the Body Corporate with false information about themselves or another personal information subject without the consent of the latter are liable as per the legislation of the Russian Federation.

5. The Body Corporate may process the following personal information of Users

5.1. Full name.

5.2. E-mail address.

5.3. Phone numbers.

5.4. Company.

5.5. The website also collects and processes anonymous information about visitors (including cookies) using web analytics services (Yandex.Metrika, Google Analytics, etc.).

5.6. The information described above is united by the general term of Personal information further in the text of this Policy.

5.7. The Body Corporate does not process certain special categories of personal informationrelated to race, nationality, political views, religious or philosophical beliefs, and intimate life.

5.8. Processing of personal information allowed for distribution, which belongs to the special categories of personal information specified in Part 1 of Art. 10 of the Information Protection Law, is allowed if the prohibitions and conditions set in Art. 10.1 of the Information Protection Law are observed.

5.9. The User's consent to the processing of personal information authorized for distribution is issued separately from other consents to the processing of the User’s personal information. In such a case, the conditions outlined in Art. 10.1 of the Information Protection Law shall be met. Requirements for the contents of such consent are established by the authorized body for the protection of the rights of personal information subjects.

5.9.1. The User explicitly provides consent to the Body Corporate for the processing of personal information authorized for distribution.

5.9.2. No later than three working days from the date of receipt of the specified User’s consent, the Body Corporate is obliged to publish information about the processing conditions, as well as any prohibitions and conditions for the processing of personal information authorized for distribution by an unlimited number of parties.

5.9.3. The transfer (distribution, provision, access) of personal information authorized by the personal information subject for distribution must be stopped immediately if requested by the personal information subject. This requirement applies to the last name, first name, patronymic (if specified), contact information(telephone number, e-mail address, or postal address) of the personal information subject, as well as the list of personal information, which processing shall be stopped. The personal information specified in such a request can be only processed by the Body Corporate to whom it is sent.

5.9.4. Consent to the processing of personal information authorized for distribution terminates from the moment the Body Corporate receives the request specified in p. 5.9.3 of this Policy regarding the Personal Information Processing.

6. Personal information processing principles

6.1. The processing of personal information shall be legal and fair.

6.2. The processing of personal information shall be limited to the achievement of specific, predetermined, and legitimate purposes. The processing of personal information incompatible with the personal information collection purposes is not allowed.

6.3. It is forbidden to combine informationbases containing personal information, which is processed for incompatible purposes.

6.4. Only such personal information that meets the processing purposes shall be subject to processing.

6.5. The content and scope of the processed personal information shall correspond to the stated processing purposes. The processed personal information must not be redundant for the stated personal information processing purposes.

6.6. Personal information processing shall ensure the accuracy and sufficiency of personal information, and relevance for the personal information processing purposes when required. The Body Corporate takes the required measures and (or) ensures that such measures are taken to delete or revise the incomplete or inaccurate information.

6.7. Personal information is stored in a form allowing the identification of the personal information subject for a period not exceeding the time required for the personal information processing purposes if the personal information storage period is not specified in the federal law or in an agreement where the personal information subject is a party, beneficiary or guarantor. The processed personal information shall be disposed of or anonymized when the processing purposes are fulfilled or in case such purposes are no longer actual unless otherwise is provided by federal law.

7. Personal information processing purposes

7.1. The User's personal information is processed for the following purposes:

to inform the User via e-mail messages;
to conclude, execute and terminate civil law contracts.

7.2. The Body Corporate also has the right to send notifications to the User about new products and services, special offers, and various events. The User can always opt out of receiving informational messages by sending an email message to the Body Corporate at info@clever-corp.com with the following message "I’m opting out of receiving notifications about new products, services, and special offers".

7.3. Anonymized User information collected via web analytics services is used to collect information about the User’s actions on the website, as well as to improve the website quality and its content.

8. Legal grounds for personal information processing

8.1. Personal information processing by the Body Corporate is legally based on the following:

statutory (constitutive) documents of the Body Corporate;
agreements concluded between the Body Corporate and the personal information subject;
federal laws and other regulatory acts related to personal information protection;
consent of Users to the processing of their personal information, as well as the processing of personal information authorized for distribution.

8.2. The Body Corporate shall process the User's personal information only if such information is filled in and (or) sent solely by the User using dedicated forms on the https://clever-corp.com/ website or sent to the Body Corporate by e-mail. The User expresses his consent to this Policy by filling in the relevant forms and (or) sending their personal information to the Body Corporate.

8.3. The Body Corporate processes anonymized information about the User if it is allowed in the User's browser settings (JavaScript and Cookies are enabled).

8.4. Personal information subjects solely decide on the provision of their personal information and give consent voluntarily, based on their free will, and in their best interests.

9. Personal information processing conditions

9.1. Personal information is processed with the consent of personal information subjects to its processing.

9.2. Personal information is processed to achieve the purposes stipulated by the international treaties of the Russian Federation or specific laws, as well as to realize the functions, as well as fulfill the powers and obligations of the Body Corporate as per the legislation of the Russian Federation.

9.3. Personal information is processed to bring justice in effect, execute a judicial act, an act of another body, or an official subject as per the legislation of the Russian Federation on legal process execution.

9.4. Personal information is processed to observe an agreement where the personal information subject is a party, beneficiary, or guarantor, as well as to conclude an agreement initiated by the personal information subject or an agreement where the personal information subject is the beneficiary or guarantor.

9.5. Personal information is processed to exercise the rights and legitimate interests of the Body Corporate or third parties, or to achieve socially significant goals provided that the rights and freedoms of the personal information subject are not violated.

9.6. To process personal information wich is provided with the unlimited access to number of parties by the personal information subjects or at their request (hereinafter referred to as publicly available personal information).

9.7. To process personal information that is subject to publication or mandatory disclosure as per federal law.

10. Procedure for collection, storage, transfer, and other types of personal information processing

The Body Corporate ensures the security of personal information by implementing legal, administrative, and technical measures necessary to fully comply with the requirements of the current legislation regarding personal information protection.

10.1. The Body Corporate ensures the secure retention of personal information and takes all possible measures to exclude access to personal information by unauthorized persons.

10.2. Under no circumstances, User’s personal information shall be transferred to third parties, except for in cases related to the compliance with the applicable law, or if the personal information subject has given consent to the Body Corporate to transfer information to a third party to fulfill obligations under a civil law contract.

10.3. If any inaccuracies are found in personal information, the User can update them independently by sending the Body Corporate a message at the Body Corporate’s e-mail address info@clever-corp.com with the subject "Personal information update".

10.4. Unless a specific period is specified by the agreement or applicable law, the personal information processing term ends upon the achievement of the purposes, for which the personal information is collected.

Users may at any time withdraw their consent to the processing of personal information by sending an e-mail message to the Body Corporate’s email address at info@clever-corp.com with the subject "Withdrawal of consent personal information processing".

10.5. All information that is collected by third-party services, including payment systems, communication software, and other service providers, is stored and processed by these parties (Body Corporates) as per their User Agreements and Privacy Policies. Personal information subjects and (or) Users are obliged to independently review the specified documents in a timely manner. The Body Corporate is not responsible for the actions of third parties, including service providers specified in this paragraph.

10.6. The prohibitions set by the personal information subject regarding the transfer (except for access granting), as well as the processing or conditions for the processing (except for obtaining access) of personal information authorized for distribution, do not apply in cases of personal information processing in the state, public and other public interests determined by the legislation of the Russian Federation.

10.7. When processing personal information, the Body Corporate shall ensure it’s confidentiality.

10.8. The Body Corporate stores personal information in a form allowing the identification of the personal information subject for a period not exceeding the time required for the personal information processing purposes if the personal information storage period is not specified in federal law or in an agreement where the personal information subject is a party, beneficiary, or guarantor.

10.9. Personal information processing may be terminated after the achievement of the personal information processing purposes, the expiration or withdrawal of the personal information subject’s consent, as well as in a case when illegal processing of personal information is discovered.

11. List of actions performed by the Body Corporate with the received personal information

11.1 The Body Corporate collects, records, categorizes, accumulates, stores, revises (updates, modifies), extracts, uses, transfers (for distribution, provision, access), anonymizes, suspends, deletes, and destroys personal information.

11.2. The Body Corporate performs automated processing of personal information with or without the receipt and (or) transmission of the received information via information and telecommunication networks.

12. Cross-border transfer of personal information

12.1. Before starting the cross-border transfer of personal information, the Body Corporate is obliged to ensure that the foreign state where the personal information will be transferred provides reliable protection of the rights of personal information subjects.

12.2. Cross-border transfer of personal information to the territory of foreign states that do not meet the above-mentioned requirements can be made only with the written consent of the personal information subject to the cross-border transfer of the personal information and (or) execution of an agreement where the personal information subject is a party.

13. Confidentiality of personal information

The Body Corporate and other persons having access to personal information are obliged not to disclose personal information to third parties and not to distribute it without the consent of the personal information subject unless otherwise is specified in federal law.

14. Final provisions

14.1. Users can receive any revises on their concerns regarding the processing of their personal information by contacting the Body Corporate at info@clever-corp.com.

14.2. This document will reflect any changes made by the Body Corporate to the Personal Information Processing Policy. This Policy is valid indefinitely until replaced by a newer version.

14.3. The current version of the Policy is publicly accessible at https://clever-corp.com/policy