Privacy Policy

The following documents details our Privacy Policy (the “Policy") and describes information that we collect about you, that you provide to us, and will be processed by us, as you use the services referred to in the Terms of Service (the “Services”) available through this https://imc.management website (the “Website”).

We understand the importance of privacy and accordingly, treat all information received in a responsible manner. By using the Services, you agree to be bound by the Policy. If you do not agree to the terms of this Policy, please do not use the Services. Each time you use the Services, the current version of the Policy will apply.

The terms “we”, “us”, “our” mean DMI Marketing Integrator Limited, a company duly registered and existing under the laws of the Republic of Cyprus.

You are accepting and consenting to the practices described in this Policy by filling and submitting the enquiry form on the Website.

How, when and what we collect?

How do we collect your information?

We collect information directly from you for the purpose of having an opportunity to contact with you.

We also use cookies when you use the Website. Please, refer to the Cookie Policy to know how and when we use cookie files.

When do we collect your information?

When you apply via the inquiry form and provide us with your personal data, you contact us with questions, and you otherwise choose to provide information to us.

Please, refer to the Cookie Policy to know how and when we use cookie files.

What information do we collect?

We collect the following types of information about you:

a) when you apply via the inquiry form on the Websitel;

• Your name;
• website of yours or a person you represent;
• A phone number;

b) when you contact with us via our official e-mails or other official contact details:

• information you provide us with. Please, note that we do not collect, process, use in any way any information about your racial or ethnic origin, political opinion, religion or beliefs, trade union membership, genetic or health status or sexual orientation. We will immediately delete information of that kind in case you provide us with it.

Please, refer to the Cookie Policy to know how and when we use cookie files.

Legal grounds for processing your personal data

We process your information based on the following legal grounds, as recognized by and in compliance with the applicable data protection laws:

• the processing of information referred in the Section “What information do we collect?” above is necessary to get in contact with you and perform communications with you. We process your personal data on the basis of your consent that you give us while filling and sending of an inquery form via the Website. In case if you want us to stop processing your information you have the right to demand so by contacting us on that matter via our contact details below.

Please, refer to the Cookie Policy to know how and when we use cookie files.

Do you have to give us your information?

If you do not provide it, you will not be able to use the Services.

We need:

• your phone – to get in contact with you;
• your name – to be able to address you proberly;
• website of yours or a person you represent – to know who or what legal entity do you represent.

How we use your information

We use your information to communicate with you.

When do we share your information

We may share your information with third parties and under the reasons mentioned below:

1) With our service providers (like server hosting provider) – to hold your information on their facilities. The complete information about our service providers is contained in the Section “WHERE WE STORE YOUR DATA” below;

2) With public and official agencies on their demand, if so required by law. We will notify you about such disclosure the fastest way possible after we receive such demand;

3) In response to legal process when required by law – to comply with the law, a judicial proceeding, subpoena, court order, or other legal process. We will notify you about such disclosure the fastest way possible after we face such need.

You should be aware that when sharing your information, it would be transferred to, and stored at, a destination outside the EEA, namely, in the Russian Federation, in scope of clause 1) of the previous paragraph. Please, refer to the section “Controller and Processor”, “Processor” below to know where do we store your information.

Please note that where data is transferred outside of the EEA, non-EEA countries may not offer the same level of protection for personal data as is available in the EEA. We will take various measures to ensure that your data is treated securely, which may include, but not be limited to:

• assessing the security measures taken at any place your data is transferred to;
• having suitable contract terms in place that oblige a data processor to only process in accordance with our instructions; and
• having monitoring, reporting and resolution procedures in place with regard to ongoing security.

Please contact us if you require more detailed information about international transfers of your information, and the particular safeguards used.

Where we store your data

All information you provide to us is stored on secure servers of our providers. You may find their contact details in section “Controller and Processor” labeled as “Processor”. Where you have chosen a password which enables you to access the personal account on the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent un-authorized access.

Profiling and automated decision making

We do not facilitate any profiling and automated decision making using personal data you provide us with.

How long do we keep your information?

We retain your information as required by applicable laws or regulations and/or until you decide to stop us from retaining your information or until retaining of your information becomes unnecessary for the purposes of your communications with us. Please, note that we will know that you want to stop using the Services only if you expressly notify us about your decision. However, we will anyway periodically review the necessity of retention of your data.

Your rights

You have several rights in relation to your personal data which are described in more detail below. You can exercise your rights at any time by contacting us at alexander@ingateglobal.com.

Accessing your data

You can ask us to:

• Confirm whether we are processing your personal data
• Give you a copy of that data

Provide you with other information about your personal data such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we carry out any automated decision making or profiling. We aim to give you all this information in this privacy policy, although if anything is unclear, please us at alexander@ingateglobal.com.

You do not have to pay a fee for a copy of your information unless your request is unfounded, respective or excessive, in which case we will charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request.

We aim to respond to you within 1 (one) month of receiving your request unless it is particularly complicated or you have made several requests, in which case we aim to respond within 3 (three) months. We will let you know if we are going to take longer than 1 (one) month in dealing with your request. If we have a lot of information about you we might ask you if you can tell us what exactly you want to receive. This will help us action your request more quickly.

Correcting your data

You can ask us to correct any data which is inaccurate or incomplete. This is free of charge.

If we have shared the data with anyone else, we will tell them about the correction wherever possible. We aim to deal with requests for correction within 1 (one) month, although it might take us up to 3 (three) months if your request is particularly complicated.

If we cannot action a request to correct your data, we will let you know and explain why this is.

Erasing your data

This right is sometimes referred to as “the right to be forgotten”. This is not an absolute right but you have the right to have your data erased, free of charge, in certain circumstances.

You can ask for your data to be erased where:

• it is no longer necessary for the purpose for which it was originally collected or processed;
• we are processing your data based on your consent, and you withdraw that consent;
• you object to the processing and we do not have an overriding legitimate interest for continuing;
• your data has been unlawfully processed;
• your data must be erased to comply with a legal obligation;
• the data was processed to offer information society services to a child.

There are some exceptions to this right. If one of these applies, we do not have to delete the data.

If we have shared your data with third parties, we will tell them about the erasure of your data unless this is impossible or would involve disproportionate effort.

Restricting the processing of your data

You can ask us to restrict the processing of your personal data in some circumstances, free of charge. This is not an absolute right. If processing is restricted we can store the data and retain enough information to make sure the restriction is respected, but we cannot further process your data.

You can restrict the processing of your personal data in the following cases:

• if you contest the accuracy of your data, we will restrict processing until we have made sure the data is accurate;
• if you object to our processing and we are considering this objection;
• if the processing is unlawful but you do not want us to erase your data;
• if we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.

If we have disclosed the data to a third party, we will inform them about the restriction unless it is impossible or would require a disproportionate effort. We will tell you if we decide to lift a restriction on processing your data.

Objecting to the processing of your data

Objecting to the processing of your data is free of charge. It is not an absolute right but you can object to our processing of your data where it is:

• based on the legitimate interests ground; or
• for the purposes of scientific/historical research and statistics.

We will stop processing your personal data unless we have compelling legitimate grounds for the processing which override your interests and rights, or unless we are processing the data for the establishment, exercise or defence of legal claims.

You can require us to stop using your data for direct marketing purposes. We will stop as soon as we receive your request. There are no exemptions or reasons for us to refuse.

Data Portability

This allows you to obtain and reuse your personal data for your own purposes across different services. It applies where the following conditions are met:

• you provided the personal data to us yourself;
• we are processing the data either based on your consent or because it is necessary for the performance of a contract; and
• the processing is carried out by automated means.

We will provide your data free of charge in a structured, commonly used and machine-readable form. We aim to provide your data within 1 (one) month of receiving your request unless it is particularly complicated or you have made several requests, in which case we aim to respond within 3 (three) months. If we are going to take longer than 1 (one) month we will let you know and explain why we need more time. If we consider that we cannot provide you with your data, we will contact you and explain why this is.

Automated decision making and profiling

We do not perform any automated decision making and profiling. However, for your information, you have the right not to be subject to a decision which is based on automated processing and which produces a legal (or similarly significant) effect on you. You have the right to:

• request human intervention;
• express your point of view;
• ask for the decision to be explained; and
• challenge the decision.

These rights are not absolute. They do not apply if the decision is:

• necessary to enter into or perform a contract with you;
• authorised by law (e.g. for fraud prevention); or
• based on your explicit consent.

Сontroller and processor

For the purposes of the General Data Protection Regulation (“GDPR”), the data controller and processor are:

Controller

We, DMI Marketing Integrator Limited of Makariou III, 20, Office 102, 6017, Larnaca, Cyprus, a company established in Republic of Cyprus with the registered number HE 361468 and regulated for data protection purposes by the Cypriot Regulatory Authority (CRA).

Processor

Money Generation Tools Limited of 121205, Russia, Moscow, territory of Skolkovo innovation center, 42 Bolshoy boulevard, bldg. 1, office 712.

If you have any questions about this Policy, please contact us at alexander@ingateglobal.com.

If you are unhappy about how we are processing your data or how we have responded to a request or complaint, you have the right to make a complaint to the CRA or your local supervisory authority. You can find more details about how to contact the CRA on their website http://www.dataprotection.gov.cy.