PRIVACY AND PERSONAL DATA PROTECTION POLICY

Actual PRIVACY AND PERSONAL DATA PROTECTION POLICY

(further – The Policy) has been drafted in accordance with the requirements of Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (Privacy and Electronic Communications Directive) and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (further –Law).

This Policy establishes the procedure for the implementation FIDELIO CONSULTING LIMITED (further –Company)processing personal data provided by customers who use the site https://robotdreams.cc/  and its individual services to receive or provide services(further – Users и Website respectively). The policy defines the types of personal data collected, the purposes of using such personal data, the Company's interaction with third parties, security measures to protect personal data, the conditions for accessing personal data, as well as contact information for the user regarding access, making changes, block or removal your personal data and dealing with any questions that may arise regarding personal data protection practices.

The Company treats with great respect the confidential (personal) information of all persons visiting the Site without exception. https://robotdreams.cc , as well as those who use the services provided by the Site; in this connection, the Company seeks to protect the confidentiality of personal data (information or a set of information about an individual who is identified or can be specifically identified), thereby creating and ensuring the most comfortable conditions for using the services of the Site for each user.

The text of the Policy is available to Users on the Internet   https://robotdreams.cc/politics  In case of disagreement with the terms of the Policy, the User must immediately stop any use of the Site.

  1. TERMINOLOGY AND ABBREVIATIONS

  1. The terminology used in this Policy means the following:

  1. Personal data - Any information relating directly or indirectly to an identified or identifiable natural person (to the subject of personal data).

  2. Company - FIDELIO CONSULTING LIMITED, registration at the address : Office no. 1D, Floor no. 6, Tower 1, Amenity Center, Al Jazeera Al Hamra, Ras Al Khaimah, ras al khaimah, 9714, United Arab Emirates

  3. Processing of personal data - Any action or set of actions performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (distribution, provision, access) , depersonalization, blocking, deletion, destruction of personal data.

  4. Automated processing of personal data - Processing of personal data using computer technology. Despite this, the automated processing of personal data does not contain a system of automatic processing, including profiling, which creates legal consequences for the User, or which in a similar way significantly affects the User

  5. Dissemination of personal data - Actions aimed at disclosing personal data to an indefinite circle of persons.

  6. Providing personal data- Actions aimed at the disclosure of personal data to a specific person or a defined circle of persons.

  7. Blocking personal data - Suspension of personal data processing (unless the processing is necessary to clarify personal data).

  8. Use of personal data - Actions (operations) with personal data performed by the Company in order to make decisions or perform other actions that give rise to legal consequences in relation to the subject of personal data or other persons or otherwise affect the rights and freedoms of the subject of personal data or other persons.

  9. Depersonalization of personal data - actions, as a result of which it becomes impossible to determine the ownership of personal data by a specific subject of personal data without the use of additional information;

  10. Destruction of personal data - Actions as a result of which it becomes impossible to restore the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed.

  11. Online program - An educational program, the training of which is carried out exclusively using distance technologies on the Company's Online Platform, available at:   https://robotdreams.cc/

  12. Online platform - The Company's software, which is a set of interconnected web services and modules that make up a single space for providing services to consumers on the Internet

  13. Free lesson - Audiovisual material (webinar), access to which, as well as to all materials of which, is provided by the Company free of charge for all Users who have registered for participation in such a webinar. The Company conducts free classes for all interested Users. A free lesson is not fully or partly an educational program

  14. Terms of use - Agreement posted on the Internet at  https://robotdreams.cc/oferta  ,  which is an offer by the Company to conclude an agreement with any third party using the Site on the terms provided for in the User Agreement.

  15. Site - A set of information, texts, graphic elements, design, images, photos and video materials and other results of intellectual activity, as well as computer programs contained in an information system that ensures the availability of such information on the Internet at a network address   https://robotdreams.cc/

  16. Personal account - Section of the Site, access to which the User receives after their registration on the Site by entering a unique login and password.

  17. Cookies - Data that is automatically transmitted to the Company in the process of using the Site using the software installed on the User's device, including IP address, geographic location, information about the browser and type of operating system of the User's device, technical characteristics of the equipment and software used by the User, date and time of access to the Site. Cookies can be permanent (they are called persistent cookies) and remain on the computer until the user deletes them, or temporary (these cookies are called session cookies), which are stored only until the browser is closed. In addition, cookies are divided into primary (they are set directly by the visited Site) and third-party (set by other sites).

  18. IP address” — is a numeric designation used by computers on a network to identify the computer each time they access the Internet.

2. Consent of the User to the processing of personal data by the Company

2.1. The user accepts the terms of the Policy and gives the Company informed consent to the processing of their personal data on the terms provided for by the Policy and the Law:

2.1.1. When registering on the Site  - for personal data that the User provides to the Company:

· by filling out the registration form located on the Internet The user is considered to have given consent to the processing of their personal data when the box is ticked ““I accept the terms of the Offer Agreement and agree to the personal data processing policy””at the moment the button is pressed “Sing up”;

· by authorization using personal data specified by the User in social networks or electronic services. The user is considered to have given consent to the processing of his personal data at the moment of pressing the button displaying the social network or electronic service selected for authorization.

By pressing this button, the User consents to the transfer to the Company of all personal data that was made public by him by indicating the relevant social network or electronic service in the profile.

2.1.2. When entering or changing personal data in the section “Personal data”, “My Interests” in the personal account - for personal data that the User provides when editing information in section “Personal data”, “My interests”  in personal account. The user is considered to have given consent to the processing of their newly entered or changed personal data at the time of clicking the “Save” button.”.

2.1.3. When filling out the feedback form - - for personal data that the User provides to the Company when filling out a feedback form on the Internet on the Site and electronic services (Google, etc.). The user is considered to have given consent to the processing of his personal data entered in the fields of the feedback form at the time of pressing the button confirming the sending of the application (buttons may be called "Submit", "Leave the application" and in other similar way).

2.1.4. When subscribing to receive information and news materials from the Company - by filling out a form for subscribing to a newsletter located on the Internet. The form Subscription becomes available for registration after passing the registration procedure. The user is considered to have given consent to the processing of his personal data by ticking  the field “ “I hereby consent to the processing of personal data” at the time of clicking. “the “Subscribe” button”.

2.1.5. Enrollment in the Online Program  - by filling in the fields of the application for registering for training, located on the Internet. The user is considered to have given consent to the processing of his personal data by tickin.“the box in the “Register for learning” form” at the time of clicking “the “Sign up” button ”.

2.1.6. When sending a scanned copy of the completed consent form for the processing of personal data by e-mail – for personal data that the User provides to the Company in order to receive educational services on the Website under the program of additional professional education. The user is considered to have given consent to the processing of their personal data at the time of sending a scanned copy of the consent to the email address with the domain name @robotdreams.cc .

2.1.7. Sign up for a free lesson - by filling in the fields of the application for making an entry located on the Internet. The user is considered to have given consent to the processing of their personal data by ticking “the box in the “Register for learning” form” at the time of clicking“the “Sign up” button.”.

2.1.8. Any use of the Site -for personal data that is automatically transferred to the Company in the process of using the Site using the software installed on the User's device. The user is considered to have given consent to the processing of his personal data at the time of the start of using the Site.

2.2. The User's consent to the processing by the Company of their personal data is valid from the date of granting consent to their processing (clause 2.1 of the Policy), and for the period necessary to achieve the goals of processing personal data (section 5 of the Policy).

2.3. The user has the right to withdraw consent to the processing of personal data in the form and procedure provided for in section 9 of the Policy.

3.Conditions for the provision of personal data by the User

Company proceeds from the fact that when providing personal data on the Site, the User:

3.1. confirms , that possesses all the necessary rights that allow him to acquire civil rights for themselves and independently exercise them, as well as the ability to create civil obligations for themselves by their actions, independently fulfill them and bear responsibility in case of failure to fulfill them;

3.2.  Indicates reliable information about yourself to the extent necessary to use the Site, and keeps the provided personal data up to date.

3.3.In case of uploading your image through the personal account of the Site - royalty-free consents to the use of this image  for purposes not related to the identification of the User. The User undertakes not to provide photographs of third parties as an image of the User.

3.4. Aware that information on the Site posted by the User about themselves may become available to other Users of the Site, may be copied and distributed by such Users in the cases and under the conditions specified in clause 6.7 of the Policy.

3.5. Familiarized with this Policy, expresses their informed consent to it.

4.Personal data processed by the Company

4.1.The personal data of the User processed by the Company includes:

1. Full Name;

2. Phone number;

3. E-mail address;

4.Account data in social networks and electronic services (links to the User's profiles in VKontakte, Facebook, Linkedin, Skype, Google, Twitter, etc.);

5. Image;

6.Place of work;

7. Country, city;

8. Date of Birth;

9. Profession;

10. Information about work experience and position held;

11.IP-address;

12. Files  cookies;

13. Options and Internet browser settings (User-agent).

4.2. The Company protects Data that is automatically transmitted while viewing ad units and when visiting pages on which the system’s statistical script (“pixel”) is installed:

IP address;

information from cookies;

browser information (or another program that provides access to display ads);

access time;

the address of the page on which the ad unit is located;

referrer (url of the previous page).

When visiting the Site, all logins to the system are recorded. Other user traffic information is not processed or stored.

4.4. The Company does not collect any information regarding the processing of which certain requirements are established by law, such as information about racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, criminal convictions for a crime or convictions for criminal punishment, as well as data relating to health, sexual life, biometric or genetic data

4.5. The Company collects data on the statistics of visits to the Site. The information may contain information about connections, traffic, the user's browser, as well as the date, time, duration of work on the Internet and being on the Site.

4.3. Any other personal information , not specified above (visit history, browsers and operating systems used, etc.) , is subject to secure storage and non-distribution.

5.Use of cookies

5.1 The Company cares about its users and tries to make the stay on the Site as comfortable as possible, and for this the Company needs, with the help of cookies, to analyze the behavior, preferences and interests of the user. Such an analysis will help the Company improve the experience of interacting with the Site, determine the most convenient interface and navigation of the Service.

5.2 According to the classification of the International Chamber of Commerce, the Company uses these categories of cookies:

Strictly necessary cookies - needed to move the user through the web page and when using certain services, for example, to access secure pages, register and log in, search the Site. Strictly necessary cookies also remember the previous actions of the user when going to the previous page in the same session.

Performance cookies - aggregate information about how the Site is used. This data is stored on the user's device between web browser sessions. Examples of such data can be the following metrics: time spent on the Site, most frequently visited pages, understanding which sections and services of the site were the most interesting for the user, how effective this or that advertising and / or marketing campaign, etc.

All information collected by performance cookies is for statistical and analytical purposes. Some cookie data may be provided to third parties who have permission from the web resource, and solely for the purposes indicated above.

Functional cookies - used to save settings or configurations that are stored on the user's device between web browser sessions. Examples of such data may include the following metrics: username, profile photo, information on comments left, site language, location, information about whether the user was provided with any information or benefits previously selected, as well as other Site settings.

These cookies also allow users to watch videos, participate in interactive activities (polls) and interact with social networks.

To improve the experience after visiting the resource, these cookies remember the information provided by the user, increasing the efficiency of interaction with the Site.

Some cookie data may be provided to third parties who have permission from the web resource, and solely for the purposes indicated above.

Targeting cookies - used to provide content that may be of interest to the user. This data is stored on the user's device between web browser sessions. Examples of such data can be the following metrics: tracking recommended text, graphics, audio and video material in order to avoid re-display, managing targeted advertising, evaluating the effectiveness of advertising campaigns, information about the user visiting other resources during transitions, as well as other settings of the Site.

The Site may share this information with other parties, including media clients, advertisers, agencies and related business partners in order for them to provide quality targeted advertising.

Cookies of third party services and analytics services:

For prompt delivery, better display and detailed analysis of the content on the Site, the Company uses services that are the property of other third-party companies such as Facebook, Twitter, Instagram, Alphabet Inc., Gemius and others.

The companies cited as an example may use cookies on the user's device while browsing the Site.

Please note that the Site cannot affect the operation of the cookies used by these services. All the necessary information about their use can be found by visiting the appropriate resource.

Google Analytics Terms of Service - http://www.google.com/analytics/terms/ru.html

Cookie management:

The main web browsers (listed below) are set to automatically accept cookies. To disable them, use the help function in your browser. Help can be accessed via the menu or using the F1 key.

Microsoft Edge — https://privacy.microsoft.com/ru-ru/privacystatement

Mozilla Firefox — https://www.mozilla.org/ru/privacy/websites/#cookies

Google Chrome — https://support.google.com/chrome/answer/95647?hl=ru

Opera — http://help.opera.com/Windows/11.50/ru/cookies.html

Safari for macOS — https://support.apple.com/kb/PH21411?locale=en_US

Important:

the configuration of cookie settings for web browsers of mobile devices may differ;

it should be recalled that full-fledged work with the Site is available only when using cookies;

disabling cookies may lead to limited access to content and to the defective functioning of the services of the Site.

To contact the Company about the use of cookies, send an email to  [email protected]

If the user does not enable the use of cookies or deliberately deletes all cookies from their web browser, then the next time they visit the Site, the user will be prompted to enable and use cookies again.

Information about users obtained using cookies is not sold or distributed in the public domain, and is also the property of the company that owns the resource.

6. Purposes of personal data processing

6.1.The Company processes Users' personal data solely for the following purposes:

6.2.1. Registration of the User by the Company on the Site, providing the User with the opportunity to fully use the services of the Site.

6.2.2. Displaying the User's profile on the Site in the personal account.

6.2.3. Establishing and maintaining communication between the User and the Company, advising on the provision of services, providing customer and technical support in case of problems related to the use of the Site.

6.2.4. Fulfillment by the Company of obligations to the User who signed up for training under the Online Program, for a Free Lesson, under agreements with the Company

6.2.5 . Sending advertising messages by the Company to the User's e-mail address; targeting advertising materials.

6.2.6. Improving the quality of service for Users and modernizing the Company's Website by processing requests and applications from the User.

6.2.7. Statistical and other studies based on depersonalized information provided by the User.

6.2.8. Placement on the Company's Online Platform, available at: https://skvot.io/, in the official groups of social networks and other communities of the Company on the Internet, other advertising and information sources, for purposes not related to the identification of the User:

· video materials received in the process of providing services,

· feedback left by the User about the services provided by the Company.

The user retains the right to unsubscribe. Then their name and email address will be automatically removed from the database. To do this, just one click of the mouse on the corresponding item, which is in each received letter, is enough.

7. Processing of personal data

7.1. The processing and storage of the provided personal data is carried out in data centers where the equipment that ensures the functioning of the Site services is located. The personal data provided is processed and may be stored in the Personal Data Base or in a separate table of the Site Database. Since the Company's servers are located in different regions around the world, the information of a particular User may be processed in a country other than the country in which they live. The level of information protection and legislation in this area may differ in different countries. Regardless of where exactly the User's data is processed, the Company uses the same security measures described in this Policy. The company also adheres to a number of data transfer laws, including the EU-US Privacy Shield Framework and the US-Swiss Agreement.Swiss-US Privacy Shield Framework.

7.2. Personal data is processed using automated systems, except when non-automated processing of personal data is necessary in connection with the fulfillment of legal requirements.

7.3. The processing of the User's personal data includes the following actions by the Company: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.

7.4.The collection of the User's personal data is carried out in the cases specified in clause 2.1 of the Policy.

7.5. The storage of personal data is carried out (depending on which event occurs first):

· until they are deleted by the User in the section;“ “My profile and programs””and “ “Settings”” of the personal account;

· until the moment of their destruction by the Company - in case of receipt from the User of the withdrawal of consent to the processing of personal data or a request for the destruction of personal data;

· until the expiration of the consent (clause 2.2 of the Policy) or the achievement of the purposes of processing personal data.

7.6. Clarification of personal data can be carried out by the User independently in the sections “Personal data”, “My interests” Personal Account or by the Company at the request of the User (clause 8.4 of the Policy)

7.7. Distribution of personal data can be carried out by the Company only in the following cases:

7.7.1. When processing personal data in order to display the User's profile for other Users of the Site to maintain communication, including when providing services remotely. (Clause 5.2.2 of the Policy). In this case, the User's personal data may be available to Users registered on the Site in accordance with clauses 2.1.4, 2.1.8.

7.7.2. In order to post reviews about the services provided by the Company, left by Users, in various sources of information.

7.7.3. For the purpose of placing video materials obtained in the process of providing services in various sources of information.

7.8. The Company has the right to transfer personal data to third parties subject to the following conditions:

· The third party ensures the confidentiality of personal data during their processing and use; undertakes not to disclose to other persons, and also not to distribute the personal data of Users without their consent.

· The third party guarantees compliance with the following measures to ensure the security of personal data during their processing: the use of information security tools; detection and recording of facts of unauthorized access to personal data and taking measures to restore personal data; restriction of access to personal data; registration and accounting of actions with personal data; control and evaluation of the effectiveness of the measures taken to ensure the security of personal data.

7.9. The destruction of personal data is carried out by the Company in the following cases:

· deletion by the User of personal data in the section“ “My profile and programs””and “Settings” of the personal account;

· receipt from the User of withdrawal of consent to the processing of personal data;

· receipt from the User of a request for the destruction of personal data;

· expiration of consent (п. 2.2 Политики).

The Company does not transfer personal data to third parties, except when such transfer is required by law, at the request of the subject of personal data or in other cases set forth in this Policy. The Company understands that personal information is valuable and integral content, including the personal non-property rights of any individual, and therefore takes all possible measures to protect the personal information of users, voluntarily and knowingly transferred by the latter to the Company.

7.10. Cross-border transfer of personal data

The Company is obliged to make sure that the foreign state, to whose territory it is supposed to transfer personal data, provides adequate protection of the rights of personal data subjects, before such a transfer begins.

Cross-border transfer of personal data on the territory of foreign states that do not provide adequate protection of the rights of personal data subjects may be carried out in the following cases:

  • availability of consent in writing of the subject of personal data to the cross-border transfer of their personal data;

  • execution of an agreement to which the subject of personal data is a party.

8. Protection of personal information

The Company takes the necessary and sufficient legal, organizational and technical measures to protect information provided by Users from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties with it. However, despite all efforts, the Company cannot guarantee absolute security against any threats arising outside the Company's regulation.

The Company uses standard operating practices such as encrypted communications, secure premises, firewall systems and password protection systems to ensure the confidentiality of personal data.

The Company provides access to information and personal data only to authorized employees who have agreed to maintain the confidentiality of such information and data in accordance with the requirements of the Company.

The Site may contain links to other websites (for informational purposes only). If you follow a link to other websites, this Policy will not apply to such sites. In this connection, the Company recommends that you familiarize yourself with the privacy and personal data policy of each site before transferring personal data by which you can be identified. Read more here

9. User Rights

The user has the right:

9.1. At its discretion, provide the Company with personal data for their processing on the terms specified in the Policy. At the same time, some of the personal data provided are necessary for the conclusion of the User Agreement, and if they are not provided, the conclusion of such User Agreement is impossible.

9.2. Independently make changes and corrections to their personal data in the section “Personal data”, “My Interests” in the personal account provided that such changes and corrections contain up-to-date and reliable information;

9.3. Delete personal data by editing a section “Personal data”, “My Interests” in the personal account;

9.4. The user has the right to require the Company to clarify their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take legal measures to protect their rights.

9.5. receive no later than thirty calendar days from the date of receipt of the request, except as otherwise provided by law, an answer on whether personal data is being processed, as well as receive the content of such personal data;

9.6 present a reasoned demand to the owner of personal data with an objection to the processing of their personal data;

9.7. Apply legal remedies in case of violation of the legislation on the protection of personal data, incl. file a complaint with a supervisory authority;

9.8. To update, access, amend, block or delete your personal data, withdraw your consent to the processing of personal data that you provided to the Company in accordance with this Policy, or in case of any comments, wishes or claims regarding your personal data that are being processed Company, please contact the Company: by e-mail [email protected]/ .

9.9. The user has the right to send companies to its requests and requirements, including the use of its personal data, as well as relevant consent to the processing of personal data. Appeal can be sent in writing at the address of the company (section 11 of policies); either by e-mail (the document should be sent from the email address specified by them when registering on the website or in the contract as an authorized email address), at the address of the company's email.   [email protected] . The company considers user handling, provides them with an answer and / or performs the necessary actions  within 30 calendar days from the date of receipt.

9.10. In addition to the rights listed in this Policy, the User has the opportunity to exercise any right provided for by the Law.

10.Policy change

10.1.The company reserves the right   Periodically, changes and additions may be made without prior notice, including changes in the requirements of legislation.

On the user lies the duty with each use of the site to get acquainted with the text of politics.

10.2. The new policies take effect from the date of its placement in the relevant section of the company's website. Continuing the use of the site or its services after the publication of the new policy of politics means making policies and its conditions by the user. In case of disagreement with policies, the user must immediately terminate the use of the site and its services.

10.3 . We ask from time to time to revise the policy in order to be aware of any changes or additions.

11. Сведения о Компании

FIDELIO CONSULTING LIMITED

Office no. 1D, Floor no. 6, Tower 1, Amenity Center,

Al Jazeera Al Hamra, Ras Al Khaimah, ras al khaimah, 9714, United Arab Emirates

Authorized email address: [email protected]