1. Introduction1.1. Our most important goal and condition for the implementation of our activities is the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Sonatra Easy Money Ltd ("Operator") policy regarding the processing of personal data ("Privacy policy") applies to all information that the Operator may receive about visitors to the
https://easymoney.money website and/or the Easy Money App.
2. Basic concepts used in the Privacy policy2.1.
Automated processing of personal data is the processing of personal data using computer technology.
2.2.
Blocking of personal data is a temporary cessation of the processing of personal data (unless the processing is necessary to clarify personal data).
2.3.
Website is a collection of graphic and information materials, computer programs and databases that ensure their availability on the Internet at the network address
https://easymoney.money.
2.4.
Mobile app is software designed to run on smartphones, tablets and other mobile devices called the Easy Money App.
2.5.
Personal data information system is a set of personal data contained in databases, which ensure their processing by information technologies and technical means.
2.6.
Depersonalization of personal data is an action as a result of which it is impossible to determine the belonging of personal data (without the use of additional information) to a specific User or other subject of personal data.
2.7.
The processing of personal data is any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, using, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.8.
Operator is a state body, a municipal body, a legal entity or an individual, independently or jointly with other persons, organizing and / or carrying out the processing of personal data. The Operator also determines the purposes of processing personal data, the composition of personal data subject to processing, determines the actions (operations) performed with personal data.
2.9.
Personal data is any information directly or indirectly related to a specific or identifiable User of the
https://easymoney.money website and the Easy Money App mobile application.
2.10.
Personal data permitted by the subject of personal data for dissemination is personal data, access to which is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Law on Personal Data (hereinafter referred to as
personal data permitted for distribution).
2.11. User is any visitor to the
https://easymoney.money website and the Easy Money App.
2.12. The provision of personal data is actions aimed at disclosing personal data to a certain person or a certain circle of persons.
2.13.
Dissemination of personal data is any action aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at acquainting with the personal data of an unlimited number of persons, including the disclosure of personal data in the media, posting on information and telecommunication networks or providing access to personal data in any other way.
2.14.
Cross-border transfer of personal data is the transfer of personal data to the territory of a foreign state to the authority of a foreign state, to a foreign natural or foreign legal entity.
2.15.
Destruction of personal data is any action as a result of which personal data is destroyed irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and (or) material carriers of personal data are destroyed.
3. Basic rights and obligations of the Operator3.1. The operator has rights:
- to receive from the subject of personal data reliable information and/or documents containing personal data, including phonebook numbers and photos;
- this data is necessary to identify the user
- we do not share your contacts with third parties- if the subject of personal data withdraws consent to the processing of personal data, then the Operator has the right to continue processing personal data without the consent of the subject of personal data (if there are grounds specified in the Law on Personal Data);
- to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The operator is obliged:
- to provide the subject of personal data, upon his request, with information regarding the processing of his personal data;
- to organize the processing of personal data in the manner prescribed by the current legislation of the country;
- to respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
- to inform the authorized body for the protection of the rights of subjects of personal data at the request of this body the necessary information within 30 days from the date of receipt of such a request;
- to publish or otherwise provide unrestricted access to this Privacy policy in relation to the processing of personal data;
- to take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
- to stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and in cases provided for by the Law on Personal Data;
- to perform other duties provided for by the Law on Personal Data.
4. Basic rights and obligations of subjects of personal data4.1. Personal data subjects have the rights:
- to receive information regarding the processing of his personal data, except for cases provided for by federal laws. The Operator in an accessible form provides the information to the subject of personal data; it cannot contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The Law on Personal Data establishes the list of information and the procedure for obtaining it;
- to require the operator to clarify his 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 measures provided by law to protect their rights;
- to put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;
- to withdraw consent to the processing of personal data;
- to appeal to the authorized body for the protection of the rights of subjects of personal data or in court the illegal actions or inaction of the Operator when processing his personal data;
- to exercise other rights provided for by the legislation of the country.
4.2. Personal data subjects are obliged to:
- provide the Operator with reliable data about himself or herself;
- inform the Operator about the clarification (update, change) of their personal data.
4.3. Persons who have transferred false information about himself or herself to the Operator, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the country.
5. The operator can process the following personal data of the User's:5.1. Full Name.
5.2. Email address.
5.3. Phone numbers, including phonebook numbers.
5.4. Year, month, date and place of birth.
5.5. Camera, media library (photo gallery/ video gallery) of the User's mobile device.
5.6. Citizenship document.
5.7. Details of the identity document.
5.8. The address of the actual place of residence and registration at the place of residence and / or at the place of stay.
5.9. Information about income.
5.10. Information about the debt.
5.11. The site and the application collect and process anonymized data about visitors (including cookies) using Internet statistics services (Google Analytics and others).
5.12. The general concept of Personal data means the above Privacy policy data.
5.13. The operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, intimate life.
5.14. The Operator is allowed to process personal data (permitted for distribution, from among the special categories of personal data specified in the Personal Data Law), only if the Operator complies with the prohibitions and conditions provided for by the Personal Data Law.
5.15. The User's consent to the processing of personal data (permitted for distribution) is drawn up separately from other consents to the processing of his personal data. At the same time, the conditions provided for in the Personal Data Law are respected. The requirements for the content of such consent are established by the authorized body for the protection of the rights of subjects of personal data.
5.15.1 The User directly provides the Operator with consent to the processing of personal data permitted for distribution.
5.15.2 The transfer (distribution, provision, access) of personal data permitted by the subject of personal data for distribution have to be stopped at any time at the request of the subject of personal data. This requirement should include the name, surname, contact information (phone number, e-mail address, postal address, phonebook numbers or photos) of the subject of personal data, as well as a list of personal data that the Operator needs to stop. Only Operator can process the personal data specified in this request.
5.15.3 Consent to the processing of personal data permitted for distribution ceases to be valid from the moment the Operator receives the request specified in clause 5.15.4 of this Privacy policy in relation to the processing of personal data.
6. Principles of processing personal data
6.1. The processing of personal data is carried out on a legal and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
6.4. Only personal data that meet the purposes of their processing is subject to processing.
6.5. The content and volume of the processed personal data correspond to the stated purposes of the processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data is ensured. The operator takes the necessary measures and / or ensures their adoption to remove or clarify incomplete or inaccurate data.
6.7. The storage of personal data is carried out in a form that allows you to identify the subject of personal data. Storage is allowed no longer than the purpose of processing personal data requires, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The operator destroys or depersonalizes the processed personal data upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.
7. Purposes of processing personal data7.1. Purposes of processing the User's personal data are:
- conclusion, execution and termination of contracts;
- providing the User with access to services, information and / or materials contained on the website
https://easymoney.money website and the Easy Money App mobile application;
- photo documents creation, creation and / or saving images and / or photos, saving media materials, saving images on the User's mobile device, displaying the User's photo in the mobile application, adding a payment template in the Easy Money App mobile application;
- using the User's phone book to verify the identity of the User in the Easy Money App mobile application.
7.2. Anonymized User data collected using Internet statistics services are used to collect information about the actions of Users on the site and in the application, to improve the quality of the site and its content.
8. Legal basis for the processing of personal data8.1. The legal grounds for the processing of personal data by the Operator are:
- statutory documents of the Operator;
- contracts concluded between the operator and the subject of personal data;
- federal laws, other regulations in the field of personal data protection;
- the consent of the Users to the processing of their personal data, to the processing of personal data permitted for distribution.
8.2. The Operator processes the User's personal data only if the User has filled in and/or sent it independently through special forms located on the website
https://easymoney.money and in the Easy Money App mobile application or sent it to the Operator by e-mail. The User agrees with this Privacy policy when he fills out the appropriate forms and/or sends his personal data to the Operator.
8.3. The Operator processes anonymized data about the User if it is allowed in the settings of the User's browser or smartphone (the storage of cookies and the use of JavaScript technology are enabled).
8.4. The subject of personal data independently decides to provide his personal data and gives consent freely, of his own free will and in his interest.
9. Conditions for processing personal data9.1. The processing of personal data is carried out with the consent of the User to the processing of his personal data.
9.2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the country or by law, for the implementation of the functions, powers and duties imposed by the legislation of the country on the Operator.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the country on enforcement proceedings.
9.4. The processing of personal data is necessary for the execution of an agreement, to which the subject of personal data is a party or beneficiary or guarantor, as well as for concluding an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be the beneficiary or guarantor.
9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, if this does not violate the rights and freedoms of the subject of personal data.
9.6. The processing of personal data is carried out, access to an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter - publicly-available personal data).
9.7. The processing of personal data is carried out, which are subject to publication or mandatory disclosure in accordance with federal law.
10. The procedure for collecting, storing, transferring and other types of processing of personal dataThe 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 the current legislation in the field of personal data protection.
10.1. The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under the contract.
10.3. In the event of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator at the Operator's e-mail address easymoney.sonatra@gmail.com marked "Updating personal data".
10.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the contract or current legislation.
At any time the User can revoke his consent to the processing of personal data by sending a notification to the Operator at the Operator's email address easymoney.sonatra@gmail.com with the note "Revocation of consent to the processing of personal data".
10.5. All information that is collected by third-party services, including payment systems, communication facilities and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy policy. The subject of personal data and / or the User is obliged to independently familiarize themselves with these documents in a timely manner. The operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.6. The prohibitions established by the subject of personal data to transfer (except for granting access), process or the processing conditions (except for obtaining access) of personal data permitted for dissemination do not apply in cases of processing personal data in the state, public and other public interests determined by the legislation of the country.
10.7. When processing personal data, the operator ensures the confidentiality of personal data.
10.8. The Operator stores personal data in a form that makes it possible to determine the subject of personal data no longer than the purpose of processing personal data requires, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
10.9. A condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data or withdrawal of consent by the subject of personal data, as well as the identification of illegal processing of personal data.
11. List of actions performed by the Operator with the received personal data11.1. The Operator collects, records, systematizes, accumulates, storing, clarifying (updating, changing), extracting, using, transferring (distributing, providing, accessing), depersonalizing, blocking, deleting and destroying personal data.
11.2. The Operator carries out automated processing of personal data with the receipt and / or transmission of the information received via information and telecommunication networks or without it.
12. Cross-border transfer of personal data12.1. Before starting the cross-border transfer of personal data, the Operator is obliged to make sure that the foreign state, to whose territory it is supposed to transfer personal data, provides reliable protection of the rights of subjects of personal data.
12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if the subject of personal data has consent in writing to the cross-border transfer of his personal data and / or the execution of an agreement to which the subject of personal data is a party.
13. Confidentiality of personal dataThe operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
14. Final Provisions14.1. The user can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator by writing to the e-mail easymoney.sonatra@gmail.com.
14.2. This document will reflect any changes in the personal data processing Privacy policy by the Operator. The Privacy policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Privacy policy is freely available on the Internet at https://easymoney.money/privacy-policyhttps://easymoney.moneyCambodia
easymoney.sonatra@gmail.com
+79141272750
Last Edited on 2021-08-27