The policy of Sapiens Solutions LLC for processing personal data of visitors to the sapiens.solutions website.

1. General Provisions

1.1. This Personal Data Processing Policy (hereinafter referred to as the Policy) established by Sapiens Solutions LLC (OGRN 5157746019206, TIN 7725294897, address: 105066, Moscow, Nizhnyaya Krasnoselskaya St., 40/12, building 2, level 4 office No. 425 ) (hereinafter referred to as Sapiens Solutions), establishes the fundamental principles, purposes, method, and criteria for processing personal data of visitors to the sapiens.solutions website (hereinafter referred to as Website Visitors), as well as measures to guarantee personal data security and protection.

1.2. This Policy was formulated in compliance with the Constitution, legislative and other regulatory legal actions of the Russian Federation in the field of personal data, and is freely available on the Sapiens Solutions website at sapiens.solutions (hereinafter referred to as the Website). 1.3. The terms used in this Policy are defined in the Federal Law of the Russian Federation No. 152-FZ ON PERSONAL DATA, which was enacted on July 27, 2006.

1.4. Sapiens Solutions assures the confidentiality of personal data received in accordance with this Policy's requirements and agrees to use it exclusively for the purposes stated in it.

2. Personal data: definition and composition

2.1. Sapiens Solutions compiles a list of personal data entitled to protection in compliance with Russian Federation Federal Law No. 152-FZ On Personal Data enacted on July 27, 2006.

2.2. Sapiens Solutions processes and protects personal data (including last name, first name, contact phone number, e-mail address and other data that the Website Visitor transfers to Sapiens Solutions through the website, e-mail or other communication channels) of the Visitors to sapiens.solutions, who have expressed Consent to the processing of personal data (hereinafter referred to as the Consent) by sending information through the selected form (hereinafter referred to as the Form) on the website page. Consent is indicated by marking the corresponding field in the Form and clicking the submit button of the Form on the website page.

2.3. Certain data about the computer from which the Website Visitor is accessing the Sapiens Solutions Website is automatically registered when browsing the Sapiens Solutions Website and downloading information from it. Sapiens Solutions collects the following information when you visit the website: the date and time you visited the website; the number and titles of pages you visited, and the length of time you spent viewing them; the IP address assigned to the device you used to access the Internet; the type of browser and operating system; and the website's URL from which the transition was made.

3. The Purposes of Personal Data Processing

3.1. The processing of personal data of Website Visitors is carried out for the following purposes:

  • identifying Website Visitors on the Website;
  • sending information to Website Visitors via e-mail or through the Visitor's personal account on the Website;
  • providing Visitors with the opportunity to receive feedback from Sapiens Solutions;
  • providing visitors with access to the Website's services, information, and/or content;
  • providing information to Website Visitors for purposes that are consistent with Russian Federation legislation and the conditions of agreements between Sapiens Solutions and the relevant Website Visitors.

4. Principles and criteria for personal data processing

4.1. Sapiens Solutions adheres to the following principles when processing personal data:

  • legality and fairness;
  • by restricting the attainment of precise, predetermined, and reasonable purposes;
  • by prohibiting the processing of personal data for purposes that are incompatible with the purposes for which it was collected;
  • by preventing the merging of databases holding personal data that are processed for purposes that are incompatible with each other;
  • the content and extent of the processed personal data must be consistent with the specified processing purposes;
  • if the duration of data storage is not specified by federal legislation, a contract to which the subject of personal data is a party, beneficiary, or guarantor, personal data is stored in a format that allows identifying the subject of personal data for no longer than is necessary for the processing purposes;
  • other principles outlined in Russian Federation personal data legislation.

4.2. Sapiens Solutions processes personal data if at least one of the following requirements is met:

  • the subject of personal data has given Consent to the processing of personal data;
  • the processing of personal data is necessary for Sapiens Solutions to exercise its rights and legitimate interests in order to achieve socially significant goals, provided that the subject of personal data's rights and freedoms are not violated;
  • the processing of personal data is required for the performance of an agreement to which the subject of personal data is a party, beneficiary, or guarantor;
  • the processing of personal data is carried out for statistical or other research purposes, subject to required depersonalization of personal data;
  • additional criteria imposed by Russian Federation personal data legislation.

5. Rights and obligations of the personal data subject

5.1. The subject of personal data has the right to:

  • request clarification of their personal data, their updating, blocking or destruction;
  • receive a list of their personal data processed by Sapiens Solutions, the source of their receipt, information about the terms of processing their personal data, including the terms of their storage, and other information about the processing of their personal data;
  • require notice of any adjustments or additions made to all people who were previously notified of his inaccurate or incomplete personal data;
  • appeal against illegal acts or omissions in the processing of his personal data in the prescribed manner.

5.2. The Website Visitor agrees to submit only accurate information about themselves.

5.3. The Website Visitor grants consent to the processing of personal data for the whole term required by Sapiens Solutions to fulfill the processing purposes.

5.4. The Website Visitor may withdraw consent to the processing of personal data by writing to Sapiens Solutions at 105066, Moscow, Nizhnyaya Krasnoselskaya St., 40/12, building 2, level 4, office No. 425, Sapiens Solutions LLC.

5.5. Individuals who, without the approval of the subject whose personal data was transferred, sent information to Sapiens Solutions through the website regarding another subject of personal data are accountable under Russian Federation law.

6. Rights and obligations of Sapiens Solutions

6.1. Sapiens Solutions will never inquire about the race, ethnicity, political opinions, religious and philosophical values, health status, or personal life of a Website Visitor.

6.2. During the processing of personal data, Sapiens Solutions has the right to collect, record, systematize, amass, store, clarify (update, alter), extract, utilize, transmit (distribute, access), depersonalize, block, delete, and destroy the Visitor's personal data.

6.3. Sapiens Solutions is not permitted to disclose personal information about Website Visitors to other parties, with the exception of the following individuals:

  • authorized state bodies within their powers;
  • individuals to whom Sapiens Solutions is required to transfer personal data in order to comply with Russian Federation legislation;
  • individuals to whom Sapiens Solutions transfers personal data in order to fulfill an agreement with the subject of personal data;
  • individuals to whom Sapiens Solutions entrusts the processing of personal data;
  • successors of Sapiens Solutions upon its reorganization;
  • other parties, with the approval of the subject of personal data.

6.4. Sapiens Solutions is not authorized to use the Website Visitor's personal data for commercial reasons without his approval. The processing of the Website Visitor's personal data for the purpose of promoting goods, works, and services on the market by making direct contact with a potential customer via means of communication is only permitted with the Website Visitor's prior consent.

6.5. Sapiens Solutions agrees to notify individuals who have received the Website Visitor's personal data that the information can only be used for the purposes for which it was provided, and to require these individuals to verify that this guideline has been followed.

6.6. Those who have access to a Website Visitor's personal information must keep it confidential.

6.7. Sapiens Solutions handles and protects the personal data of Website Visitors in accordance with the provisions of this Policy, as well as other guidelines issued by Sapiens Solutions.

7. Protecting and securing personal data

7.1. To safeguard the information given by Website Visitors from unauthorized access, disclosure, distortion, blockage, or destruction, Sapiens Solutions employs adequate technological and operational security measures.

7.2. Sapiens Solutions has implemented the following measures:

  • the appointment of a person in charge of organizing the processing of personal data;
  • the implementation of legal, technical, and organizational safeguards to protect personal data;
  • an evaluation of the potential harm to personal data subjects in the event of a breach of legal requirements, the harm-to-benefit ratio, and Sapiens Solutions' security measures;
  • familiarization of Sapiens Solutions workers who process personal data directly with the provisions of Russian Federation personal data regulation;
  • command over the safeguards put in place to protect personal data.

7.3. Only approved Sapiens Solutions employees have access to personal data, and they are committed to keeping the information confidential.

8. Personal data storage

8.1. Website visitors' personal data is kept for as long as is necessary for the purposes for which it was supplied or as long as is required by law.

8.2. The personal data of Website Visitors is erased once the purposes have been reached or the term for processing personal data has expired.

9 Log data, cookies, and web beacons

9.1. The Sapiens Solutions website collects standard session log data, such as IP address, browser type, and language, as well as information on the time of visit and the websites from which links were clicked. Sapiens Solutions may use cookies (small text files stored in the visitor's browser) or web beacons (electronic images) in conjunction with tracking pixels, allowing the Platform to count the number of visitors to a particular page and provide access to certain cookies, in order to ensure effective management of the Website and assist in customizing the user interface.

The sample data gathered is exclusively for statistical purposes. Sapiens Solutions does not utilize personal information to identify visitors to our website. When registering users for access to the Website, Sapiens Solutions may combine this information with data collected through data analysis tools and cookies to evaluate how visitors use the Web.

9.2. By using the Website, the Visitor grants Sapiens Solutions permission to place cookies on the Visitor's device in line with the terms set out above.

9.3. By visiting the browser settings, the visitor has the power to control cookies. All data regarding the Visitor's choices, including the desire to refuse the usage of cookies, will be destroyed if cookies are removed. If you disable cookies, the user interface may be affected, and certain features of the Website may become inaccessible.

10. Final Provisions

10.1. This Policy may be modified at Sapiens Solutions' discretion at any time or in the event of relevant amendments or additions to the Russian Federation's current personal data legislation. The most up-to-date version of the Sapiens Solutions Policy may always be found at sapiens.solutions.

10.2. All relationships with Sapiens Solutions pertaining to the processing and protection of personal data that are not expressly addressed in this Policy are governed by the laws of the Russian Federation's current personal data legislation.

10.3 The person responsible for arranging Sapiens Solutions's processing of personal data is in charge of ensuring that the requirements of this Policy are met.

The Policy was last updated on September 14, 2020.

The policy of Sapiens Solutions LLC for processing personal data of visitors to the sapiens.solutions website.

1. General Provisions

1.1. This Personal Data Processing Policy (hereinafter referred to as the Policy) established by Sapiens Solutions LLC (OGRN 5157746019206, TIN 7725294897, address: 105066, Moscow, Nizhnyaya Krasnoselskaya St., 40/12, building 2, level 4 office No. 425 ) (hereinafter referred to as Sapiens Solutions), establishes the fundamental principles, purposes, method, and criteria for processing personal data of visitors to the sapiens.solutions website (hereinafter referred to as Website Visitors), as well as measures to guarantee personal data security and protection.

1.2. This Policy was formulated in compliance with the Constitution, legislative and other regulatory legal actions of the Russian Federation in the field of personal data, and is freely available on the Sapiens Solutions website at sapiens.solutions (hereinafter referred to as the Website). 1.3. The terms used in this Policy are defined in the Federal Law of the Russian Federation No. 152-FZ ON PERSONAL DATA, which was enacted on July 27, 2006.

1.4. Sapiens Solutions assures the confidentiality of personal data received in accordance with this Policy's requirements and agrees to use it exclusively for the purposes stated in it.

2. Personal data: definition and composition

2.1. Sapiens Solutions compiles a list of personal data entitled to protection in compliance with Russian Federation Federal Law No. 152-FZ On Personal Data enacted on July 27, 2006.

2.2. Sapiens Solutions processes and protects personal data (including last name, first name, contact phone number, e-mail address and other data that the Website Visitor transfers to Sapiens Solutions through the website, e-mail or other communication channels) of the Visitors to sapiens.solutions, who have expressed Consent to the processing of personal data (hereinafter referred to as the Consent) by sending information through the selected form (hereinafter referred to as the Form) on the website page. Consent is indicated by marking the corresponding field in the Form and clicking the submit button of the Form on the website page.

2.3. Certain data about the computer from which the Website Visitor is accessing the Sapiens Solutions Website is automatically registered when browsing the Sapiens Solutions Website and downloading information from it. Sapiens Solutions collects the following information when you visit the website: the date and time you visited the website; the number and titles of pages you visited, and the length of time you spent viewing them; the IP address assigned to the device you used to access the Internet; the type of browser and operating system; and the website's URL from which the transition was made.

3. The Purposes of Personal Data Processing

3.1. The processing of personal data of Website Visitors is carried out for the following purposes:

  • identifying Website Visitors on the Website;
  • sending information to Website Visitors via e-mail or through the Visitor's personal account on the Website;
  • providing Visitors with the opportunity to receive feedback from Sapiens Solutions;
  • providing visitors with access to the Website's services, information, and/or content;
  • providing information to Website Visitors for purposes that are consistent with Russian Federation legislation and the conditions of agreements between Sapiens Solutions and the relevant Website Visitors.

4. Principles and criteria for personal data processing

4.1. Sapiens Solutions adheres to the following principles when processing personal data:

  • legality and fairness;
  • by restricting the attainment of precise, predetermined, and reasonable purposes;
  • by prohibiting the processing of personal data for purposes that are incompatible with the purposes for which it was collected;
  • by preventing the merging of databases holding personal data that are processed for purposes that are incompatible with each other;
  • the content and extent of the processed personal data must be consistent with the specified processing purposes;
  • if the duration of data storage is not specified by federal legislation, a contract to which the subject of personal data is a party, beneficiary, or guarantor, personal data is stored in a format that allows identifying the subject of personal data for no longer than is necessary for the processing purposes;
  • other principles outlined in Russian Federation personal data legislation.

4.2. Sapiens Solutions processes personal data if at least one of the following requirements is met:

  • the subject of personal data has given Consent to the processing of personal data;
  • the processing of personal data is necessary for Sapiens Solutions to exercise its rights and legitimate interests in order to achieve socially significant goals, provided that the subject of personal data's rights and freedoms are not violated;
  • the processing of personal data is required for the performance of an agreement to which the subject of personal data is a party, beneficiary, or guarantor;
  • the processing of personal data is carried out for statistical or other research purposes, subject to required depersonalization of personal data;
  • additional criteria imposed by Russian Federation personal data legislation.

5. Rights and obligations of the personal data subject

5.1. The subject of personal data has the right to:

  • request clarification of their personal data, their updating, blocking or destruction;
  • receive a list of their personal data processed by Sapiens Solutions, the source of their receipt, information about the terms of processing their personal data, including the terms of their storage, and other information about the processing of their personal data;
  • require notice of any adjustments or additions made to all people who were previously notified of his inaccurate or incomplete personal data;
  • appeal against illegal acts or omissions in the processing of his personal data in the prescribed manner.

5.2. The Website Visitor agrees to submit only accurate information about themselves.

5.3. The Website Visitor grants consent to the processing of personal data for the whole term required by Sapiens Solutions to fulfill the processing purposes.

5.4. The Website Visitor may withdraw consent to the processing of personal data by writing to Sapiens Solutions at 105066, Moscow, Nizhnyaya Krasnoselskaya St., 40/12, building 2, level 4, office No. 425, Sapiens Solutions LLC.

5.5. Individuals who, without the approval of the subject whose personal data was transferred, sent information to Sapiens Solutions through the website regarding another subject of personal data are accountable under Russian Federation law.

6. Rights and obligations of Sapiens Solutions

6.1. Sapiens Solutions will never inquire about the race, ethnicity, political opinions, religious and philosophical values, health status, or personal life of a Website Visitor.

6.2. During the processing of personal data, Sapiens Solutions has the right to collect, record, systematize, amass, store, clarify (update, alter), extract, utilize, transmit (distribute, access), depersonalize, block, delete, and destroy the Visitor's personal data.

6.3. Sapiens Solutions is not permitted to disclose personal information about Website Visitors to other parties, with the exception of the following individuals:

  • authorized state bodies within their powers;
  • individuals to whom Sapiens Solutions is required to transfer personal data in order to comply with Russian Federation legislation;
  • individuals to whom Sapiens Solutions transfers personal data in order to fulfill an agreement with the subject of personal data;
  • individuals to whom Sapiens Solutions entrusts the processing of personal data;
  • successors of Sapiens Solutions upon its reorganization;
  • other parties, with the approval of the subject of personal data.

6.4. Sapiens Solutions is not authorized to use the Website Visitor's personal data for commercial reasons without his approval. The processing of the Website Visitor's personal data for the purpose of promoting goods, works, and services on the market by making direct contact with a potential customer via means of communication is only permitted with the Website Visitor's prior consent.

6.5. Sapiens Solutions agrees to notify individuals who have received the Website Visitor's personal data that the information can only be used for the purposes for which it was provided, and to require these individuals to verify that this guideline has been followed.

6.6. Those who have access to a Website Visitor's personal information must keep it confidential.

6.7. Sapiens Solutions handles and protects the personal data of Website Visitors in accordance with the provisions of this Policy, as well as other guidelines issued by Sapiens Solutions.

7. Protecting and securing personal data

7.1. To safeguard the information given by Website Visitors from unauthorized access, disclosure, distortion, blockage, or destruction, Sapiens Solutions employs adequate technological and operational security measures.

7.2. Sapiens Solutions has implemented the following measures:

  • the appointment of a person in charge of organizing the processing of personal data;
  • the implementation of legal, technical, and organizational safeguards to protect personal data;
  • an evaluation of the potential harm to personal data subjects in the event of a breach of legal requirements, the harm-to-benefit ratio, and Sapiens Solutions' security measures;
  • familiarization of Sapiens Solutions workers who process personal data directly with the provisions of Russian Federation personal data regulation;
  • command over the safeguards put in place to protect personal data.

7.3. Only approved Sapiens Solutions employees have access to personal data, and they are committed to keeping the information confidential.

8. Personal data storage

8.1. Website visitors' personal data is kept for as long as is necessary for the purposes for which it was supplied or as long as is required by law.

8.2. The personal data of Website Visitors is erased once the purposes have been reached or the term for processing personal data has expired.

9 Log data, cookies, and web beacons

9.1. The Sapiens Solutions website collects standard session log data, such as IP address, browser type, and language, as well as information on the time of visit and the websites from which links were clicked. Sapiens Solutions may use cookies (small text files stored in the visitor's browser) or web beacons (electronic images) in conjunction with tracking pixels, allowing the Platform to count the number of visitors to a particular page and provide access to certain cookies, in order to ensure effective management of the Website and assist in customizing the user interface.

The sample data gathered is exclusively for statistical purposes. Sapiens Solutions does not utilize personal information to identify visitors to our website. When registering users for access to the Website, Sapiens Solutions may combine this information with data collected through data analysis tools and cookies to evaluate how visitors use the Web.

9.2. By using the Website, the Visitor grants Sapiens Solutions permission to place cookies on the Visitor's device in line with the terms set out above.

9.3. By visiting the browser settings, the visitor has the power to control cookies. All data regarding the Visitor's choices, including the desire to refuse the usage of cookies, will be destroyed if cookies are removed. If you disable cookies, the user interface may be affected, and certain features of the Website may become inaccessible.

10. Final Provisions

10.1. This Policy may be modified at Sapiens Solutions' discretion at any time or in the event of relevant amendments or additions to the Russian Federation's current personal data legislation. The most up-to-date version of the Sapiens Solutions Policy may always be found at sapiens.solutions.

10.2. All relationships with Sapiens Solutions pertaining to the processing and protection of personal data that are not expressly addressed in this Policy are governed by the laws of the Russian Federation's current personal data legislation.

10.3 The person responsible for arranging Sapiens Solutions's processing of personal data is in charge of ensuring that the requirements of this Policy are met.

The Policy was last updated on September 14, 2020.