Privacy Policy
This Privacy Policy (the "Privacy Policy") is designed to provide data subjects with information on the processing of their personal data (any information relating to them) by JSC Positive Technologies (TIN 7718668887) ("Positive" or "we" or "us" or "our"). We protect business and government entities (the “Customers”) from non-tolerable events using the latest technologies of cybersecurity. We do that through our own legal entities as well as through our authorized partners (the "Partners"). We also believe in the importance of education, which is why we conduct training and educational courses and programs where we teach participants of such courses and programs, who can be individuals as well as representatives of legal entities (the "Participants"). For the purposes of this Policy, by Participants we also mean participants of various events and contests held by us.
This Privacy Policy contains important information about, among others, the collection and use of your personal data; the legal grounds for the processing of that data; disclosures of that personal data to third parties and the use of cookies by Positive. Privacy policy also covers the processing of personal data by our website https://rules.ptsecurity.com/ ("Website").
This Privacy Policy is based on the provisions of data protection laws, which may be applicable in the country of your residence.
1. Controller
This Privacy Policy applies when we act as a data controller with regard to your personal data.
Our address: 107061, Russia, Moscow, Preobrazhenskoye municipal district, Preobrazhenskaya pl., 8, room. 60.
Data subjects can contact us on any questions relating to the processing of their personal data under this Privacy Policy by e-mail: privacy@ptsecurity.com or by sending the request on our address.
2. Categories of processed personal data
We may process the following personal data depending on the circumstances of our interaction with you. The table below sets out the categories of personal data we process.
| Category of data | Description |
|---|---|
Data necessary for providing our services to Customers, Partners and Participants | Full name, phone number, e-mail address, identifiers in messengers and social networks, job title, structural unit and current place of employment, personal identifiers, data on technical means (devices) such as IPs, information automatically received from our services, including cookies, information received as a result of your actions, including information about comments, requests, feedback, and questions you have sent to us |
Marketing data | Full name, phone number, e-mail, identifiers in messengers, job title, structural unit and current place of employment |
Feedback data | Full name, phone number, email address, identifiers in messengers, information about comments, requests, reviews and questions you have sent |
Data automatically collected by our Website | Cookies |
3. Purposes and legal bases for the processing
We process your personal data only when we have one of the legal bases mentioned below: 3.1. Performance of the Contract. We may process your personal data to provide you with our services under the contract between you / your company.
3.2. Legitimate Interest. We may process your personal data when we (or a third party) have an interest in using your personal data in a certain way, which is necessary and justified in light of the possible risks.
3.3. Consent. Where required by applicable laws, we will process your personal data based on your consent.
3.4. Legal Obligations. When we must process your personal data to comply with applicable laws.
3.5. Other. We can also process your personal data to exercise our legal rights or on the other legal bases provided by applicable law.
The table below sets out:
- Positive’s purposes for processing of personal data;
- Positive’s legal basis for each purpose under applicable law;
- categories of personal data which Positive uses for each purpose.
| Purpose of processing | Legal basis | Categories of personal data used for the purpose |
|---|---|---|
To provide our services to our Customers, Partners and Participants | Contract / Legitimate interest | Data necessary for providing our services to Customers, Partners and Participants |
To market, promote, and advertise our services | Consent / Legitimate interest | Data necessary for providing our services to Customers, Partners and Participants, Marketing data |
To process feedback from you | Contract / Legitimate interest / Consent | Feedback data |
To improve our services, including to train ML models | Legitimate interest | All data |
To comply with legal obligations and law enforcement requests | Legal obligation / Legitimate interest | All data |
To establish, exercise, or defend legal claims | Legitimate interest / other | All data |
To detect and prevent fraud | Legitimate interest | All data |
To provide security | Legitimate interest | All data |
To conduct research, contests, surveys | Contract / Legitimate interest / Consent | Data necessary for providing our services to Customers, Partners and Participants, Marketing data, Feedback data |
We do not process your personal data for other purposes that are not covered by this Privacy Policy.
4. Recipients and sources of personal data
4.1. We disclose certain personal data to the following recipients to the extent required or permitted by applicable law and/or based on their legitimate and reasonable requests:
- payment services providers;
- sales and marketing services providers;
- service providers, otherwise assisting in provision of our services and achievement of other purposes mentioned in the section 3 of the Privacy Policy;
- affiliate entities of Positive which are a part of the same group of companies
- • governmental and regulatory bodies, including law enforcement authorities, in connection with enquiries, proceedings or investigations by such parties or in order to enable Positive to comply with its legal and regulatory requirements.
4.2. We obtain personal data through any information you provide directly to us or through information provided by third parties. Below is a list of ways in which we collect your personal data.
Personal data collected directly from you, including:
- when you use our Website;
- when you contact us for any enquiries, complaints or for any other reason.
Personal data collected from other sources, including:
- via third parties including in a manner that is permitted.
5. Transfers to third countries
We may transfer personal data of the data subjects to third countries that do not provide the same level of data protection as in the country of your residence. When doing so, we ensure implementation of security measures aimed at protection of your personal data in an appropriate manner.
You can get more information on the mechanisms of transfers to third countries by Positive by sending a request with the use of contact details specified in section 1 of this Privacy Policy.
6. Storage periods
We store personal data as long as it is required to achieve the purposes of the processing specified in section 3 of this Privacy Policy, unless there are specific periods defined in applicable laws.
If you wish to have any personal data removed from our databases, please contact us by sending a request with the use of contact details specified in section 1 of this Privacy Policy.
7. Basic rights of data subjects
Please see your rights and their descriptions in this table. Please note that the list of available rights may vary depending on the law applicable to the relationship between you and the Positive.
| Right | Description |
|---|---|
Access | You can ask us to confirm whether or not we process your personal data. If so, you can access these personal data and ask us to explain certain details of the processing. |
Marketing data | Full name, phone number, e-mail, identifiers in messengers, job title, structural unit and current place of employment |
Rectification | You can ask us to correct inaccurate personal data concerning you. If it complies with the purposes of the processing, you can ask us to rectify incomplete or inaccurate personal data. |
Erasure ("right to be forgotten") | You can ask us to erase personal data concerning you under applicable law. For example, this applies if (1) the personal data are no longer necessary in relation to the purposes for which they were processed; (2) you withdraw consent to the processing and there is no other legal ground for the processing; (3) the personal data have been unlawfully processed. |
Restriction on processing | You can ask us to mark the stored personal data with the aim to limit their processing in the future under applicable law. This applies if (1) you contest the accuracy of the personal data; (2) you ask to restrict the use of the personal data when their processing is unlawful; (3) you need personal data to protect your rights when our services no longer needs the personal data; (4) you have objected the processing based on the legitimate interests pursued by us or by a third party. |
Objection to processing | You can object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on the legitimate interests pursued by Positive or by a third party. We shall no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. |
Portability | When the processing is based on your consent or on the agreement with you, you can receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format and can freely transmit those data to another controller. Where technically feasible, the data subject can also ask us to transmit the personal data directly to another controller. |
To exercise these rights, you can contact us with the use of contact details specified in section 1 of this Privacy Policy.
8. Withdrawal of consent
Where processing is based on consent (or explicit consent), you have the right to withdraw consent at any time. The withdrawal of consent does not affect the lawfulness of the processing based on consent before its withdrawal. We can continue to process your personal data if we have another legal basis to do so. To withdraw consent, you can contact us with the use of contact details specified in section 1 of this Privacy Policy.
9. Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with a supervisory authority in the area of data protection in the country of your residence.
10. Cookies
| Type of cookies | Description |
|---|---|
Strictly necessary | These cookies are necessary for the functioning of our websites and cannot be disabled. As a rule, they are activated only in response to your actions similar to requesting services, such as setting up a privacy level, logging in or filling out forms. You can configure your browser to block these cookies or notify you about their use, but in this case, it is possible that some sections of our websites will not work or will not work correctly. |
Targeting | These cookies are set up through our websites by our advertising partners. They can be used by these companies to collect data about your interests and display relevant advertisements for you on other websites. If you do not approve the use of these cookies, you will not be shown our targeted advertising on various websites. |
Operational | These cookies allow us to count the number of visits and traffic sources in order to evaluate and improve the performance of our websites. Thanks to them, we know which pages are the most and least popular, and we see how visitors navigate through websites. |
Functional | These cookies allow you to provide improved functionality and personalization, for example for online chats and videos. They can be configured by us or by third-party providers whose services are contained on our pages. If you do not approve the use of these cookies, it is possible that some or all of these functions will not work properly |
To opt out of the use of the relevant cookies, you have the right to use the functionality of our Website intended for this purpose. You also have the right to use your browser settings, where you can disable the use of cookies. Detailed instructions on how to disable cookies are available via external links:
In addition, the Yandex.Metrica service is used to collect and statistically analyze data related to the use of the Website. The data collected by Yandex.Metrica can be received and processed by the provider of this service (Yandex LLC). The list of data collected using Yandex.Metrica can be found here.
11. Children’s privacy
We do not knowingly or intentionally collect personal data through our services from children under eighteen (18) years of age. If you are under eighteen (18) years of age / other age, recognized in your jurisdiction as sufficient for your use of our services, do not attempt to register for or use of our services, do not provide us any personal data about yourself unless you have the requisite parental consent. If you are a parent or guardian and you are aware that your child has violated this Privacy Policy and provided us personal data, please contact with the use of contact details specified in section 1 of this Privacy Policy. If we become aware that a minor has provided us personal data or we otherwise process his personal data in violation of the Privacy Policy, we will take steps to remove that information.
12. Changes to this Privacy Policy
We may change this Privacy Policy from time to time at our sole discretion. If so, we may notify the data subjects about these changes by an appropriate method. If there is no explicit notification, the data subjects may always review the up-to-date version of this Privacy Policy.
