Privacy Policy - Alfabank-Adres

Privacy Policy Statement

This Privacy Policy explains how Alfabank-Adres Pty Ltd. and its Affiliates (collectively "Alfabank-Adres", "we" or "us") may Services collect, and process your personal information. This Privacy Policy applies to alfabank-adres.ru and other Alfabank-Adres related sites, apps and services (the "Services"). In certain sites operated overseas, the privacy policy displayed on those websites, and not this Privacy Policy, may govern the collection, use and sharing of information Personal data, or personal information, which means any information about an individual from which that person can be identified ("Personal Data"). We reserve the right to amend the Privacy Policy at any time. The date of the last revision to the Privacy Policy will be indicated by the "Effective Date" date at the bottom of this page.

We follow principles in accordance with the General Data Protection Regulation (the "GDPR") and worldwide practices for customer privacy and data protection.

How to Contact Us

If you have any questions about our Privacy Policy or handling of your Personal Data, please contact the us by email at data.protection.office@alfabank-adres.ru.

Or by mail at: Alfabank-Adres, Attn: Data Protection Officer, 1251-55 Electric Ave, Venice, CA 90291

Where We Collect Your Data From

We may collect Data in the following ways:

Data you give to us:

Data you give to us when you become a client and use our services
When you use our website
In emails to us or when you inquire about our Service
When you give us feedback

Data we collect when you use our services:

Payment information collected by our vendor to process payment for our Service
Usage data, including data we gather from the devices you use to connect to those services such as computers and mobile phones, using cookies (please see our separate cookie policy) and other internet tracking software

Data from third parties:
Public information sources such as LinkedIn & ZoomInfo

Types of Information We Collect:
Personal Data: We may collect, use, store and transfer many kinds of Personal Data, which we have grouped together as follows:

Identity Data: name, company email address
Contact Data: company email address, company billing address, , company title or telephone number
Financial Data: payment card details (we use a third-party service to process payments)
Technical Data: internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites
Usage Data: information about how you use our products, services and website
Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences

Aggregated Data:
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data, but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature.

Special Categories of Personal Data: We will not collect any categories of special categories of personal data about you including details about race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data, and information about criminal convictions and offences. We do not collect data relating to children.

How We Use Your Data

We only use Personal Data, this includes when we share your information with third parties, if we have a legal basis to do so. Our legal basis is as follows:

to fulfil a contract we have with you
when it is our legal duty
when it is in our legitimate interest
when you consent to it

We have set out in the table below the Personal Data which we collect from you, how we use it, and the legal basis (or bases) on which we rely when we use the personal information. If we are relying on our legitimate interests, we have set that out in the table below.

What we use your personal information for	What personal information we collect	Our legal grounds for processing	Our legitimate interests (if applicable)
To register you as a new client	Identity data, Contact data, Financial data, Marketing and communications data	Performance of a contract with you, Our legitimate interests, Your consent	Keeping our records up to date, working out which of our services may interest you and telling you about them
To manage our relationship with you or your business	Identity data, Contact data, Marketing and communications data	Performance of a contract with you, Our legitimate interests	Seeking your consent when we need it to contact you, Being efficient about how we fulfil our legal and contractual duties
To study how our clients use our services including submitting surveys	Identity data, Contact data, Marketing and communications data	Our legitimate interests, Our legal duty, Your consent	Developing services, and what we charge for them, Defining types of clients for new services, To study how clients use our services, to develop them, to promote and grow our business and to inform our marketing strategy
To communicate with you about our services	Identity data, Contact data, Marketing and communications data	Your consent, Our legitimate interests	Keeping our records up to date, working out which of our services may interest you and telling you about them, Developing services, and what we charge for them, To assess the health of our relationships with business contacts
To manage relationships with our business contacts	Identity data, Contact data, Marketing and communications data	Your consent, Our legitimate interests	Keeping our records up to date, working out which of our services may interest you and telling you about them, Developing services, and what we charge for them, To assess the health of our relationships with business contacts
To administer and protect our business and our website	Usage data, Technical data	Fulfilling contracts, Our legitimate interests	Being efficient about how we fulfil our legal and contractual duties
To use data analytics to improve our website, services, marketing, client relationships and experiences	Usage data	Performance of a contract with you, Our legitimate interests	Being efficient about how we fulfil our legal and contractual duties
To exercise our rights set out in agreements or contracts	Identity data, Contact data, Financial data	Performance of a contract with you, Our legitimate interests	Being efficient about how we fulfil our legal and contractual duties
To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, adding and testing systems and processes, managing communications, corporate governance, and audit	Identity data, Contact data, Financial data	Our legitimate interests, Our legal duty	Complying with rules and guidance from regulators, Being efficient about how we fulfil our legal and contractual duties
To manage payments and collect and recover money that is owed to us	Identity data, Contact data, Financial data	Performance of a contract with you, Our legitimate interests	Being efficient about how we fulfil our legal and contractual duties, Complying with rules and guidance from regulators
To develop new ways to meet our clients’ needs and to grow our business	Identity data, Contact data, Financial data, Marketing and communications data	Performance of a contract with you, Our legitimate interests, Our legal duty	Developing products and services, and what we charge for them, Defining types of clients for new services, Being efficient about how we fulfil our legal and contractual duties

How We Share Your Data

We do not sell your personal information that is collected under this Privacy Notice.

We may share Personal Data with the following for the purposes of providing the Services which you have requested from us:

agents and advisers that we use such as tax auditors;
our Affiliates;
regulators or authorities if required by law;
third party companies who help us manage our electronic communications to our customers
third party companies that help us provide the Service to you. For example, we use vendors for our internal customer services management platform or to process payments. Additionally, we use third party companies that provide applications/functionality, data processing or IT services to us. For example, we use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. These include providers of IT services, cloud-based software-as-a-service providers, website hosting and management, data analysis, data back-up, security and storage services.
You can find details of how these third parties use your Personal Data by looking at their privacy policies.
We request third parties who we share your information with to respect the security of your Personal Data and to treat it in accordance with the law. We only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
We may also share your Personal Data if we are under a duty to disclose or share that information in order to comply with any legal obligation, or in order to enforce or apply our terms of use, or to protect our rights, property, or safety, our clients, or others.

Transferring Your Data

We are an international organization with our Affiliates located around the world, including the United States and Australia. Additionally, we use third parties located outside the European Union to help us run our business. For the use of our services, your Personal Data will be transferred to the United States or Australia where our servers are located. By submitting your Personal Data to us, you agree to the transfer, storage and processing of your Personal Data in the United States and Australia.

We will only transfer your data to:

to fulfil a contract we have with you; or
when it is our legal duty; or
when it is in our legitimate interest; or
when you consent to it.

If we do transfer your personal information, we will make sure that it is protected by ensuring we have contracts in place to protect your Personal Data.

Data Security

We have put in place appropriate technical and organizational security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will keep your Personal Data for as long as you are our client.

After you stop being a client, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for one or more of the following reasons:

To respond to any questions or complaints from you;
To maintain our records;
To comply with laws and rules applicable to us

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

With respect to personal data, which we receive and process in order to comply with our legal requirements, we retain such personal data for a period of five years from the end of the matter we are handling for you or from the date upon which you cease to be our client. In most cases we will retain the personal data in accordance with our file retention policy of two years from the date of the file being archived but we may do so for longer if necessary.

Your Rights

Certain Individuals may have rights which are set out in the law relating to your Personal Data. Such rights include:

Getting a copy of the information we hold

You can ask us for a copy of the Personal Data that we hold about you, by contacting us using the details set out above. This is known as a data subject access request. You will not have to pay a fee to access your personal data, unless we believe that your request is clearly unfounded, repetitive or excessive. In such circumstances, we can charge a reasonable fee or refuse to comply with your request. We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month and, in that case, we will notify you and keep you updated.

Telling us if information we hold is incorrect

You have the right to question any information we hold about you that you think is wrong or incomplete. Please contact us using the details set out above if you want to do this and we will take reasonable steps to check its accuracy and, if necessary, correct it.

Telling us if you want us to stop using your personal information

You have the right to:

object to our use of your personal information (known as the right to object); or
ask us to delete the personal information (known as the right to erasure); or
request the restriction of processing; or
ask us to stop using it if there is no need for us to use it (known as the right to be forgotten)

There may be legal reasons why we need to keep or use your Personal Data, which we will tell you if you exercise one of the above rights.

Withdrawal of your Consent

You have a right to withdraw your consent to us using your Personal Data at any time. Please contact us using the details set out above if you want to withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services.

Where we rely on our legitimate interest

In cases where we are processing your Personal Data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your Personal Data.

Request a transfer of data

You may ask us to transfer your Personal Data to a third party. This right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.

Making a Complaint

Please let us know if you are unhappy with how we have used your Personal Data by contacting us using the details set out above. If you are located in the European Economic Area, you may also have a right to complain to the Information Commissioner’s Office. You can find their contact details at www.ico.org.uk

Cookies and Other Tracking Technology

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used by us in order to make the Alfabank-Adres websites work, or work more efficiently, as well as to provide information to us about visitors' use of the Alfabank-Adres websites. Most web browsers allow some control cookies through the browser settings. To find out more about cookies, including how we use third party analytics tools, to see what cookies have been set and how to manage and delete them, please refer to our Cookie Policy.

Third party Links

Our Services may contain links to third-party websites that are not subject to this Privacy Policy. We provide these links solely for your convenience. We do not maintain these third-party websites and are not responsible for their privacy statements.

Affiliates

The Affiliates are defined as a nominated operator for Alfabank-Adres in the specified country.

U.S.A. Alfabank-Adres Inc.
U.S.A. ProcurementIQ, a Division of Alfabank-Adres, Inc.
Australia Alfabank-Adres Pty Ltd
Germany Alfabank-Adres GmbH
United Kingdom Alfabank-Adres Ltd