1. General provisions

This Privacy policy (hereinafter referred to as the "Policy") was approved and is effective in the limited liability company "Utrace" (hereinafter referred as "Utrace", registered at the address: 197101, Saint Petersburg city, Bolshaya Monetnaya street, 16, building 5, E, premises 5.

This Policy is publicly available and is placed at the address https://utracesolutions.com
Utrace, acting as the personal data controller, complies with confidentiality principle in relation to its visitors and gives it the highest priority.

This Practice contains information types, collected and recorded when visiting website utracesolutions.com (hereinafter referred to as the "website"), including information, related identified and identifiable persons, means and purposes of use thereof, personal data protection measures taken and your contact details.


2. Consent

When visiting and using our website, you consent to this Policy and the terms hereof.

Please, be aware that when using or sending personal details you may also be asked to confirm in electronic form your consent to this Policy, by clicking "I accept". Your affirmative action when clicking "I accept" and/or your website use means that you give your consent to collection, use and transfer of your personal data, as described in this Policy. The records of your consent to this Policy, its date and all future updates of this Policy shall be considered as incontrovertible written evidence of your consent.

You also agree to exercise your rights and obligations for the purposes of the website use (including, inter alia, collection, use, processing, storage and operation of personal data) in accordance with all the applicable data protection and confidentiality laws, as well as other legal regulations, including the Data Protection Directive 95/46 / EC and implementing local laws, such as Federal law No.152-FZ "Concerning personal data" dated 27.07.2006 (DPA), which may be amended, replaced or cancelled, including the General Data Protection Regulation (EC) 2016/679 dated April 27, 2016 (GDPR), effective from May 25, 2018 (hereinafter referred to as the "Data protection laws").

This Policy forms the integral part of the website use terms. When you accept the terms of use, you also approve this Privacy policy.


3. Information types we collect

3.1. Information you provide

Personal information you were asked to provide and the reason for provision thereof, will be clear to you at the moment when we ask you to provide your personal information.

In the course of registration, access or use of the website we can ask personal data about you (i.e. any information, related to you as an identified or an identifiable person) or about your employee(s), agent(s), representative(s). These data may include:

• name;
• position;
• company’s name;
• registration and/or residence address;
• e-mail address;
• telephone number;
• contents of messages and/or attachments you may send to us;

• as well as any other information you may provide to us.

3.2. Automatic data collection

With your consent, when the law requires it, new and our third party service providers may use different technologies, which collect and provide information about how the website was accessed and how it was used. Such information may include your web-browser type, operation system, service provider, viewed web-pages, time and duration of viewing thereof, demographic information about you (e.g. your age, sex, language, location and areas of interest, if available) and what web-pages you viewed before the current page. We use this information for better understanding of how our users interact with our website, and then for corresponding customization and improvement of our website. As a rule, this information cannot be connected to you personally, but if we can relate it to you, we will consider it your personal data in accordance with this Policy.

3.2.1. Log files
Utrace follows standard procedure of using the log files. These files register visitors when they visit websites. All the hosting companies do this and form the part of hosting services analytics. Information, collected by the log files, includes Internet protocol addresses (IP), browser type, Internet Service Provider (ISP), date and time mark, landing/exit pages and, maybe, click number. It is not related to any information, allowing to identify a person. Information purpose is to analyze trends, manage the website, trace movements made by the users on the website and collect demographic information.

3.2.2. Cookie files and web beacons

Just like any other website, utrace.com uses cookie files. These cookie files are used to store information, including preferences of visitors and website pages the visitor goes or went to. Information is used to optimize the users’ work by setting up of our website contents based on the visitors’ browser type and/or other information.

Out cookie files do not have an option and cannot be infiltered on your hard drive for collection confidential information. Our cookie files are not “spyware”. Most internet browsers are initially set up to accept cookie files. To receive more information about cookie files, please, read “What are cookie files?”

As cookie files allow using certain important functions of our website, we recommend leaving them turned on. By clicking “Ok” on the website banner of cookie files, your consent to use cookie files and similar technologies in accordance with your current settings of cookie files.

You can always revoke your consent and change your choice by changing settings of your browser in future to refuse from cookie files from the websites or to delete cookie files from your hard drive. If you switch off cookie files we use, this may affect your interaction with the website, in particular, you will not be able to get access to certain parts of website or use it.


4. Purposes and legal grounds for collection and processing of personal data

We use information we collect, in different ways, including the following purposes:
• render services on provision, operation and support of our website;
• improvement, personalization and extension of our website;
• analysis of your website use;
• develop new products, services, functions and functionalities;
• communicate to you directly or through one of our partners, including render services to the clients to provide you updates and other website related information and with marketing and advertising purposes;
• send you emails;
• reveal and prevent fraud.

Personal data processing by Utrace is necessary for the performance of a contract between Utrace and its clients (article 6, 1., (b) GDPR dated May 25, 2018).
If you do not provide above mentioned personal data, you cannot visit website and receive Utrace services.

We can use your personal data to accomplish other legal purposes, disclosed to you when providing your personal data or in accordance with other authorized or binding requirements for compliance with the applicable laws and regulations. In this case such personal data will be processed, as processing is necessary for legal interests, advanced by Utrace or other third parties, except where such interests are overridden by the interests or fundamental rights and freedoms (article 6, 1., (f) GDPR dated May 25, 2018).


5. Data transfer

Following provisions of section 4 of this Policy to achieve the abovementioned purposes Utrace may transfer personal data:
• to the third party service providers, acting in our name under our instructions, who render services to us, such us professional advice and Internet-related services.
• excluding the cases, directly mentioned in this Policy, Utrace will not provide your personal data to other third parties without your written consent, excluding the cases, when this is required under provisions of law or resolutions of law enforcement, controlling authorities or court.
In particular, Utrace may disclose your personal data in the following cases:

– responses to requests filed by law enforcement or court authorities, as well as in cases, required or permitted by law;
– reaction to emergency situation; or
– otherwise to protect rights, ownership, safety or protection of third parties, website visitors or public.

Certain abovementioned recipients may by located in countries outside the EEA, which are not considered to ensure adequate protection level.

In any case Utrace will transfer personal data only to the recipients, who ensure adequate level of data protection or in accordance with the data protection laws in compliance with the corresponding safety measures, including, inter alia, corresponding data protection agreements based on the EU Commission standard. Contractual provisions of data transfer to the third countries (article 46, 2., (c) GDPR).

Only a limited number of persons in Utrace (e.g. general director, project manager) gets access to your personal data based on business need.

Our website may contain links to other websites for your convenience and information. This Policy does not cover other advertisers or websites. Thus, we recommend you reading corresponding Privacy policies of these third party advertising servers to receive more detailed information. These websites are operated independently from us. Utrace is not liable for any use if such websites and for any data protection and confidentiality techniques, related to such websites.

Third party advertising servers or advertising networks use technologies, such as cookie files, JavaScript, web beacons, used in their corresponding advertisements and links on the website and sent directly to the user’s browser. When this happens, they receive your IP address automatically. These technologies are used for their advertising campaigns performance measurement and/or for personalization of advertising contents you see on the websites you visit. Please, pay your attention that Utrace has no access or control over these cookie files, used by the third party advertisers.

You may switch off cookie files in settings of your browser. You can find more details about cookie files management in certain browsers on corresponding browser websites.


6. Data protection

Utrace acknowledges and claims that any third party service providers and/or personal data processor, acting on behalf and under instructions of Utrace, take corresponding legal, technical and organizational measures to protect personal data from accidental or unlawful destruction or accidental loss, unlawful use, unauthorized access, disclosure, change or destruction, as well as against any other unlawful forms of information processing, as defined in the applicable data protection laws.

Please, note that no electronic transfer or storage of information is 100% safe. So, notwithstanding the safety measures we apply to protect your personal data, we cannot guarantee that incorrect use or change of data will never happen.

One of Utrace priorities is to protect children when using the Internet. We call parents and guardians to supervise, participate and/or control and direct their actions on the Internet. Utrace deliberately does not collect personal information, allowing to identify children below 13. If you believe your child provided such information on our website, we strongly recommend you to contact us immediately and we will do our best to immediately delete such information from our records.


7. Third party data

If (i) you provide us personal data of your representatives and/or any other persons and/or (ii) such personal data is transferred to you or by you outside the EEA in a country, not recognized as the country which ensures adequate protection level, you undertake and guarantee that you have notified such persons of collection, use and transfer of their personal data by us for the purposes and in accordance with the procedure, described in this Policy. You have also notified them of their rights, as described in section 10 below, and, in accordance with the Data protection law, and if necessary, you shall receive their express consent to processing and transfer of their personal data according to this Policy.


8. Data retaining period

Your personal data will not be stored longer than necessary for the purposes of this Policy. As a rule this period does not exceed 10 (ten) years, if shorter or longer periods of storage are not applied under the effective legislation.


9. Change and update of this Policy

Excluding the cases, provided for by the applicable laws, Utrace retains the right at own discretion to change, modify and/or supplement the entire or parts of this Policy at any time. Any change to this Policy will be published on this page and sent to you by email (if necessary or required by the law and to the extent of your email address availability). In the upper side of this Policy we will indicate the date of last update.


10. User’s rights

You as an individual whose personal data is processed under provisions of this Policy, have the following rights:

10.1. Right to revoke consent:
If you provided consent to any personal data processing action, as described in this Policy, you may revoke this consent at any time from the revocation day to any other future day. Such revocation does not affect lawfulness of processing prior to consent revocation.

10.2. Access right:
You are entitled to receive from us confirmation as to whether your personal data is being processed and in this case request access to such personal data, including, inter alia, categories of corresponding personal data, purposes of processing and recipients or categories thereof. We should actually take into account rights and freedoms of others, so this is not an absolute right. If you want to request more than one copy of personal data, we may charge reasonable fee, based on administrative expenses.

10.3. Right to correct:
You are entitled to claim that we correct or supplement inaccurate or incomplete personal data, related to you.

10.4. Right to be erased (“right to be forgotten”):
You are entitled to claim that we delete your personal data under certain circumstances, as defined in accordance with the effective legislation.

10.5. Right to restrict processing:
Under certain circumstances, as defined in the effective legislation, you are entitled to claim that we restrict processing of your personal data.

10.6. Right to object to processing:
Under certain circumstances, as defined in the effective legislation, you are entitled to object to processing of your personal data under certain conditions.

10.7. Right to data portability:
You are entitled to claim that we transfer collected data to other organization or directly to you under certain circumstances, as defined in accordance with the effective legislation.

Please, be aware that exercise of these rights is governed by certain requirements and terms, stipulated in the effective legislation.

If you want to get access to your personal data or exercise any of the rights, listed below, you should file a written request to a contact person in section 11 below. Utrace shall respond to such request within 1 (one) month from the day of such request.


11. Contact information

If you have any question related to our Policy, or if you want to get access to your personal data or use any of the rights, listed in section 10 above, send a written request

at the address:
115088, г. Moscow city, Sharikopodshipnikovskaya street, 38, building 1

or by telephone number:
+7 (495) 995-83-00

or by email:
info@utracesolutions.com

You should provide proof of your identity to exercise any of the rights, listed in section 10 above.

Any message from us in relation to your rights, described in details in section 10 above, will be provided free of charge. But in case of clearly unreasonable or excessive requests, in particular, due to their repeated character, Utrace may charge reasonable fee taking into account administrative expenses for information delivery or communication or performance of requested actions; or refuse from acting at request. Please, let us know about any complaints against your personal data processing in Utrace as the data controller. You will also be entitled to file such complaint to a competent authority, in particular, in a country of your usual residence, place of work or assumed GDPR violation.
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