Personal Data Processing Policy

Personal Data Processing Policy

1. General provisions

This personaldata processingpolicy is compiled inaccordance with the requirements of Federal Law No.152-FL "On Personal Data" dated 07/27/2006 and defines the procedure for processing personal dataand measuresto ensure the security of personal data by the site up-smm.com (hereinafter referred to as the Operator). 

1.1 The operator sets as its most important goal and condition for the implementation of its activities the respect for human and civil rights and freedoms in the processing of their personal data, including the protection of the rights to privacy, personal and family secrets.

1.2 This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors of the website up-smm.com

2. Basic concepts used in the Policy

2.1 Automated processing of personal data – processing of personal data using computer technology;

2.2 Blocking of personal data – temporary termination of the processing of personal data (except the cases where processing is necessary to clarify personal data);

2.3 A website – a combination of graphic and informationalmaterials, as well as computer programs anddatabases that ensure theiravailability on the Internetat a networkaddress up-smm.com;

2.4 The personal data information system – a combination of personal data contained in databases, and information technologies and technical means that ensure their processing;

2.5 Anonymization of personal data — actions that result in making it impossible to determine, without the use of additional information, the ownership of personal data by a specific User or another subject of personal data.

2.6 Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transmission (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data;

2.7 Operator — a governmental body, municipal body, legal entity, or individual that independently or jointly with others organizes and/or performs the processing of personal data. The Operator also determines the purposes of processing personal data, the set of personal data subject to processing, and the actions (operations) performed with personal data;

2.8 Personal data — any information directly or indirectly related to a specific or defined User of the website up-smm.com;

2.9 User — any visitor to the website up-smm.com;

2.10 Providing personal data — actions aimed at disclosing personal data to a specific individual or a specific group of individuals;

2.11 Distribution of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transmission of personal data) or providing access to personal data to an unlimited number of persons, including publication of personal data in mass media, placement in information and telecommunication networks, or providing access to personal data by any other means;

2.12 Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to an authority of a foreign state, foreign individual, or foreign legal entity.

2.13 Destruction of personal data — any actions resulting in the irreversible elimination of personal data, making it impossible to restore the content of personal data in the personal data information system, and/or the physical carriers of personal data are destroyed.

3. The Operator may process the following personal data of the User

- Surname, first name, patronymic (if applicable)

- Email address

- Phone numbers

- Year, month, date, and place of birth

Additionally, the website collects and processes anonymized data about visitors (including "cookie" files) using internet analytics services (such as Yandex.Metrica, Google Analytics, and others).

The above-mentioned data are further referred to in this Policy under the general term "Personal data."

4. Purposes of processing personal data

The purposes of processing the User's personal data include: Informing the User by sending electronic emails; Identifying the User who filled out the feedback form and/or provided data using the Website and its functional features; Providing potential clients with the opportunity to respond to offers of interest and/or sending data to up-smm.com if the potential client is interested in further collaboration.

4.2 Additionally, the Operator has the right to send notifications to the User about new products and services, special offers, and various events. The User can always opt out of receiving informational messages by sending an email to the Operator at info@up-smm.com with the subject line "Opt-out from notifications about new products, services, and special offers."

4.3 Anonymized data of Users collected through internet analytics services are used to gather information about Users' actions on the website, to improve the quality of the site, and its content.

5. Legal grounds for processing personal data

5.1 The Operator processes the User's personal data only if it is filled out and/or submitted by the User themselves through special forms located on the website up-smm.com. By filling out such forms and/or submitting their personal data to the Operator, the User expresses their consent to this Policy.

5.2 The Operator processes anonymized data about the User if it is permitted in the settings of the User's browser (enabled cookie storage and JavaScript technology usage).

5.3 Procedure for collection, storage, transmission, and other types of processing of personal data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

- The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.

- The User's personal data will never, under any circumstances, be transferred to third parties except in cases required by applicable law.

- In case of inaccuracies in the personal data, the User can update them independently by sending a notification to the Operator at the Operator's email address info@up-smm.com with the subject "Updating personal data."

The term of processing personal data is unlimited. The User may withdraw their consent for the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address info@up-smm.com with the subject line "Withdrawal of consent for processing personal data."

6. Cross-border transfer of personal data

6.1 Before initiating cross-border transfer of personal data, the Operator must ensure that the foreign state, to which the transfer of personal data is intended, provides reliable protection of the rights of personal data subjects.

6.2 Cross-border transfer of personal data to foreign states that do not meet the above requirements can only be carried out if there is written consent from the personal data subject for the cross-border transfer of their personal data and/or if it is necessary for the performance of a contract to which the personal data subject is a party.

7. Final provisions

The User can receive any clarifications on matters concerning the processing of their personal data by contacting the Operator via email at info@up-smm.com.

Any changes to the policy for processing personal data by the Operator will be reflected in this document. The policy remains in effect indefinitely until replaced by a new version.

The current version of the Policy is freely accessible on the Internet at up-smm.com.