The current version is published on June 4th, 2021.
Current version available at: https://imagion.org/docs/en.docx
1. Regulation Area.
Please note that use of any of the Products may be subject to additional terms and conditions, which may amend and/or supplement this Policy, and/or have specific terms and conditions regarding Personal Information posted in the relevant sections of the documents for such Products.
2. Information Processor.
3. What is the purpose of this Policy
The protection of your Personal Information and your privacy is extremely important to ImagiON. Therefore, when you use the Products, ImagiON protects and processes your Personal Information strictly in accordance with applicable laws.
In keeping with our obligation to protect your Personal Information, in this Policy we would like to inform you in the most transparent way possible about the following points:
1) why and how ImagiON processes your Personal Information when you use the Products;
2) what ImagiON's role and responsibilities are as the legal entity deciding why and how to process your Personal Information;
3) what tools you may use to reduce the amount of Personal Information ImagiON
4) what your rights are under the processing of your Personal Information.
4. What Personal Information ImagiON collects about you
ImagiON may collect the following categories of Personal Information about you during your use of the Products:
1) Personal Information provided by you when you register (create an account), such as your name, phone number, address and age;
2) electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser ID data, hardware and software information, wi-fi network data);
3) the date and time you accessed the Products;
4) information about your activity while using the Products (e.g., search history, data about purchases on the Products, data about organizations visited, likes and preferences, email addresses of your correspondents, phone book data, information about interactions with other users, and files and content stored on ImagiON systems);
5) geolocation information;
6) other information about you that is required to be processed under the terms and conditions governing the use of specific ImagiON Products;
7) information about You that we receive from our Affiliates pursuant to the terms of the agreements between You and the relevant Affiliate and the agreements between ImagiON and the Affiliate.
ImagiON does not knowingly collect sensitive personal information (such as racial origin, political views, health information, and biometric data) except as provided in the user agreements of individual Products. You may, however, provide this information to ImagiON on your own, in which case ImagiON will process it as part of the provision of the Products to you (for example, if you ask for search queries relating to your health). You should note, however, that ImagiON cannot ask for your consent to such processing because it is not aware in advance of the potentially sensitive nature of the Personal Information that you may provide to ImagiON.
ImagiON does not collect data for the purpose of compiling a "profile" of a user to the extent that it might materially affect your rights and freedoms under applicable law.
5. What is the legal basis and purpose for processing your Personal Information
ImagiON may not process your Personal Information without sufficient legal grounds. Therefore, ImagiON shall process your Personal Information only if:
1) the processing is necessary to fulfill ImagiON's contractual obligations to you, including making the Products work (e.g., providing you with search results for your search queries);
2) the processing is necessary to comply with statutory obligations;
3) where required by applicable law, the processing is necessary to safeguard ImagiON's legitimate interests where such processing does not materially affect your interests, your fundamental rights and freedoms. Please note that when processing your personal information on the above grounds, ImagiON will always seek to maintain a balance between its legitimate interests and protecting your privacy.
ImagiON processes your Personal Information to safeguard its legitimate interests, such as the following:
1) to better understand how you interact with our Products;
2) to improve, change, personalize, or otherwise enhance the Products for the benefit of all users;
3) to offer you other products and services from ImagiON or other companies that we think may be of interest to you (i.e., to show you advertisements that are tailored to your interests);
4) for specific purposes or as required by applicable law, we may request your separate consent to process your Personal Information. For jurisdictions where consent is recognized as a separate legal basis, your use of ImagiON Products constitutes your consent to such processing. We hereby inform you, and you acknowledge, that you are under no obligation to provide us with any Personal Information when you use the Products and that it is based solely on your free will. However, you understand that without providing Personal Information, we will not be able to provide you with the Products.
ImagiON always processes your Personal Information for specific purposes, and only Personal Information that is relevant to achieving those purposes. Specifically, we process your Personal Information for the following purposes:
1) providing you with access to the Products (including providing you with search results in response to your search queries based on your preferences, search history, and other Personal Information about you available to ImagiON);
2) Providing access to your account, including ImagiON's email account and file storage, if you are registered with the applicable Products;
3) Communicating with you to send you notices, inquiries, and information regarding the operation of the Products, to fulfill agreements with you, and to process your inquiries and requests;
4) Personalizing advertisements and offers based on your preferences, search history, and other Personal Information about you available to ImagiON;
5) enhancing the usability of the Products, including to display the most relevant search results and provide more personalized Products, and to improve other ImagiON products, applications and Products;
5) creating new ImagiON products, utilities and offerings;
7) protecting your rights and the rights of ImagiON;
8) collecting, processing and presenting statistical data, big data and other research.
The use in ImagiON Products of information obtained from the Google API (the "Received Data") shall be in accordance with the provisions of the Google API Disclosure, subject to the limitations set forth therein, as follows:
The Received Data shall be used solely for the purpose of providing you with email client features. Obtained data may not be used to transfer to third parties, to show promotional materials and for other purposes related to unauthorized access to the content of your correspondence.
6. How ImagiON protects your Personal Information
In most cases, Personal Information is processed automatically without access to it by anyone at ImagiON. Should such access be necessary, it may be granted only to those ImagiON employees who need it to perform their tasks. To protect and ensure data confidentiality, all employees must follow internal policies and procedures regarding the processing of Personal Information. They must also follow all technical and organizational security measures in place to protect your Personal Information.
ImagiON has also implemented adequate technical and organizational measures to protect Personal Information from unauthorized, accidental or unlawful destruction, loss, alteration, fraudulent use, disclosure or access, and other unlawful forms of processing. These security measures were implemented taking into account the state of the art, the cost of their implementation, the risks associated with the processing and the nature of Personal Information.
7. Where your Personal Information is stored and processed
Your Personal Information will be stored in the Russian Federation.
Imagion performs recording, systematization, accumulation, storage, clarification (update, change), extraction of personal data of citizens of the Russian Federation using databases located in the Russian Federation. In particular, all users' Personal Data is first received, processed and destroyed on servers leased by ImagiON under a contract with Yandex.Cloud Limited Liability Company, for which a certificate of compliance with ISPN requirements for security of information and personal data is obtained. The certificate certifies that the platform fully meets all the requirements of FZ-152, government decree № 1119 and order of the FSTEC № 21 and provides the first level of protection of processed personal data (UZ-1).
If you are located in a territory where your consent is required for the transfer of your Personal Information to another jurisdiction, by using the Products you are giving ImagiON your explicit and unambiguous consent to such transfer or storage, and/or processing of information in other specified jurisdictions, including Russia.
8. How long we keep your Personal Information
ImagiON will retain your Personal Information for as long as necessary to accomplish the purpose for which it was collected or to comply with legal and regulatory requirements.
Unless otherwise required by law or by agreement with you, emails and documents you store on ImagiON's systems as part of the Product will be retained for as long as you have an account, but they may be deleted by you at any time.
If you wish to have any of your Personal Information deleted from ImagiON's databases, you may delete the required Personal Information yourself using your account or through the Products interface (where applicable).
9. Your Rights
9.1 What rights do you have?
To the extent permitted by applicable law, you have the right to access your Personal Information processed by ImagiON in accordance with this Policy.
If you believe that any information that ImagiON holds about you is incorrect or incomplete, you may log into your account and correct your Personal Information yourself.
If required by applicable law, you have the right to:
- Become familiar with the information that ImagiON holds about you;
- Request the deletion of your Personal Information, or part of it, and withdraw your consent to the processing of your Personal Information;
- Request restrictions on the processing of your Personal Information;
- request a copy of the Standard Contractual Terms permitting transfer of your Personal Information to Russia and specified in Section 8 of this Policy;
- object to processing of your Personal Information, if required by applicable law.
ImagiON will comply with such requests in accordance with applicable law.
You may also have other rights not specified above, to the extent permitted by applicable law.
When you use the Products, the transfer of Personal Information is done with your free consent and interest (in particular, as a contract with you) and is not required by law.
9.2 How you can exercise your rights
To exercise your rights as set out above, please log in to your account, and if there is no special feature in the interface, contact ImagiON (see section 12 of this Policy).
If you are dissatisfied with the way ImagiON handles your Personal Information, please let us know and we will consider your complaint. If you are not satisfied with ImagiON's response, you have the right to file a complaint with a competent authority.
10. Updates to this Policy
This Policy may be amended. ImagiON may make changes at its sole discretion, including, but not limited to, where the relevant changes relate to changes in applicable law, and where the relevant changes relate to changes in the operation of the Products.
ImagiON agrees not to make any material changes to, or impose additional burdens or limitations on, your rights set forth in this Policy without notice to you. You will be notified of such changes. Appropriate notices may be displayed on the Product (for example, through a pop-up window or banner) before such changes take effect, or may be sent to you through other communication channels (for example, by email if you have provided us with your contact information).
11. Questions and Suggestions
ImagiON welcomes your questions and suggestions regarding the implementation or amendment of this Policy. Please use our feedback form located at firstname.lastname@example.org. You may also use this address to make inquiries about your rights or complaints regarding the incorrectness of your Personal Information or the illegality of its processing.