Low-power long-range (LPWAN) solutions for IoT and M2M
Low-power long-range (LPWAN) solutions for IoT and M2M

Privacy Policy

 1. Introduction / Definitions


Who we are

1.1. We are the Limited liability company “Telematics Solutions”, incorporated under the laws of the Russian Federation, primary state registration number 5167746320044. Our address: 121205, Skolkovo Innovation Centre, 42/1, Bolshoy Boulevard, a part of premises 334, working place 1, floor 1, Moscow, Russia. Our phone: +7 (499) 557-04-65, our e-mail: info@waviot.com.

1.2. You can contact our representative in the European Union by email info@waviot.com or by phone +7 (499) 557-04-65.

1.3. You can contact our personal data processing inspector by email at privacy@waviot.com or by calling +7 (499) 557-04-65.

What we do

1.4 We are engaged in the development of NB-Fi communication technology and the development, implementation and support of utilities metering devices (hereinafter referred to as the Resources) – electricity, water, heat, gas meters and other devices (probes and sensors), as well as modems for connection to such devices sending data using NB-Fi technology (hereinafter also referred to as the Device).

The devices collect data on the amount of Resources consumed and data from probes and sensors, and send them to servers for storage and processing. Software is installed on the servers (hereinafter also referred to as the Software), which processes the data received, structures it and demonstrates the processing results through the personal account on https://waviot.com or on subdomains of this website (hereinafter referred to as the Website), as well as via mobile applications developed by the Operator for use on devices with Android or iOS operating systems, and published by the Operator in the online stores of the corresponding operating systems (hereinafter referred to as the Mobile Application), to you or the company that accepts the data on the Resources consumed, or payment for the Resources consumed (for example, a resource-supplying organization or an organization that manages your apartment building, condominium, cottage village, etc.), or data from other devices that transmit data to the server (hereinafter referred to as the Supplier).

This allows you to control the amount of Resources you consume, eliminates the need to take readings from the meters yourself and report them to the Suppliers, or let representatives of the Suppliers to the apartment to do it for you, as well as receive data from other Devices that transmit data to our server.

Who you are

1.5. You are an adult in the territory of the European Union who:

(a) has purchased and installed the Device or lives in the premises where the Device is installed, and

(b) intends to use the Device and Software and/or the Website or the Mobile Application for their functional purpose, and

(c) has entered or will enter into an agreement with us on the use of the Software and/or the Website and the Mobile Application (hereinafter referred to as the Terms and Conditions), and/or

(d) has entered into or will enter into an agreement with the Supplier (or a person similar to it), under the terms of which the Supplier transfers Resources to you (or provides/arranges such transfer in your interests), and you pay for them (hereinafter referred to as the Agreement), or you permanently or temporarily live in the premises, the owner/legal owner of which has entered into the Agreement.

What you are reading now

1.6. Privacy Policy (hereinafter referred to as the Policy) is this document posted on the website page on the Internet at: https://waviot.com/en/privacy-policy, designed to process your personal data (hereinafter referred to as the Data).

In May 2018, new European General Data Protection Regulation (GDPR) comes into effect, replacing the 1995 EU Data Protection Directive. It ushers in a new era, unifying data protection rules across Europe, strengthening the rights of EU citizens and placing new obligations on all organizations that offer goods and services online. We are committed to complying with the GDPR across all of the services that we provide. We have always worked hard to demonstrate that our services are secure and meet the standards of applicable data protection rules. We offer transparency to users through clear explanations of how we use personal data.

Below the policy describes what information about you we process, for what purposes, on what basis and how. We will also explain what rights you have as a personal data subject and how to use them.

Restriction Concerning Children

1.7. We do not provide services to children (i.e., persons under 18 years of age or other age at which a person is considered an adult in your country) and do not intend to process their personal data, as the Devices, Software, Website and Mobile Application are not designed for use by children.

However, we cannot reliably check your age when you visit the Website, register a personal account on the Site, or in the Mobile Application, therefore we assume that when you start using the Website or register your personal account on the Website or in the Mobile Application, you confirm that you are 18 years old (or the age after which a person in your country is considered an adult). If you are under 18 years old (or the age after which a person is considered an adult in your country), we ask you to leave our Website, not to use the Software and Mobile Application, not to fill out the registration forms on our Website and Mobile Application, not to mark the checkboxes in the fields “I accept the terms of the Policy” / “I agree to the processing of my personal data for [purpose]” / other similar fields and not to transfer your personal data to us in any other way, and not to express your consent to their processing.

2.  Data about You that We Process and Their Sources



2.1.
If you are a visitor to our Website, we process your cookies. For more information on how we collect and receive them see Section 7 of the Policy. If you send us information using the feedback forms posted on the Website or in the Mobile Application, in addition to this, we process your full name and your contact details (phone and/or email address).

2.2. If we process your data in connection with ensuring the functioning of the Devices, used to account for the consumed Resources, we process the following categories of Data:

2.2.1. Your full name (including last name, first name and, if applicable, patronymic).

2.2.2. Address of the premises owned or occupied by you and personal account.

2.2.3. Your contact information, namely the phone number and email address.

2.2.4. The code word you use for verbal communication with us, as well as recording your conversations with our call center.

2.2.5. Readings of the Devices, the collection of data from which we provide (including data on the period of resources consumption and the time of transmission of the corresponding information).

2.2.6. Data from other Devices (for example, modems, probes and sensors) that transmit data to our server.

2.2.7. Serial and other identification numbers, as well as the types and technical characteristics of the Devices, namely:

(a) counters using which we collect data on the resources consumed;

(b) modems and similar devices that transmit data from/to such counters;

(c) other devices that receive and transmit data from or to the Operator’s server.

2.3. We obtain the above data from the following sources:

2.3.1. You provide them directly to us, including in cases when you have entered into an Agreement with us or have provided your consent.

2.3.2. If you do not provide this data directly, we can get it from the Supplier. However, this does not prevent their clarification and updating based on the data provided by you (see clause 6.24. of the Policy).

2.3.3. We can collect the information about counters, modems and other equipment, as well as readings obtained with them on our own, as a company that implements and operates such equipment, or do it via our subsidiaries, branches/representative offices or contractors (dealers, agents, representatives, etc.), if this is stipulated by the organizational features of the provision of services to you or the Supplier.

2.4. In addition to the information specified in clause 2.2 of the Policy as we add to our Services the function of payment for the services provided by us or by the Supplier, we can also collect data on fees for our services or Resources you use. We are talking only about the cases when the use of such Resources is accounted for suing the equipment and software provided and maintained by us.

The composition of such data on payments will include information on the amount of payments, and the details of payments. Such data will be provided directly by you or the bank or payment service, which you use to make a payment.

2.5. We do not process personal data that discloses racial or ethnic origin, political opinions, religious beliefs or philosophies, membership in a trade union, as well as genetic data, data relating to health, sexuality, or sexual orientation. If, in spite of this, we receive such data from you, we will delete them.

2.6. The recording of your voice, which may relate to the biometric data used for identification purposes, is processed by us only in the cases and for the purposes specified in clauses 6.24.2 – 6.24.4, 6.30 of the Policy. In other cases, the biometric data received from you will not be used for identification purposes and will be deleted.

3. What is the Basis and for What Purposes Do We Process Your Data?


Terms and Conditions

3.1. We process the data necessary to register you in your personal account on the Website or via the Mobile Application, as it is necessary for the fulfillment of the Agreement, and your use of the functionality of the Software and the Website.

3.2. If you do not provide us with such data, then:

(a) we will not be able to execute an Agreement with you and will not be able to provide you with access to your personal account to use the functionality of the Software, the Website (in terms of those functional features that are available only through a personal account) and the Mobile Application;

(b) this will not affect the validity of the Agreement (unless otherwise provided in the Agreement) and your right to consume Resources and your duty to pay for them.

Terms and Conditions and Agreement

3.3. We process the data specified in clauses 2.1 – 2.2.2, 2.2.5 – 2.2.7, as it is required for the compliance with the Terms and Conditions and may be necessary for the fulfillment of the Agreement.

3.4. By processing such Data, we will be able to save data on the Resources you use on the servers, structure it using software, then show you and the Supplier via your personal account on the Website or in the Mobile Application, and the Supplier will be able to use this Data to calculate the payment for the Resources consumed and the implementation of other rights and obligations provided for in the Agreement.

3.5. If you do not provide us with such Data (as well as require you to delete it or limit its processing), then this will not affect the validity of the Agreement (unless otherwise provided therein). Therefore, your right to consume Resources, and your duty to pay for them will remain the same. However, this will reduce the functionality of the Site, Mobile Application and software, since neither the Supplier nor you can use the software, the personal account on the Website and the Mobile Application to track the amount of resources you use – in this case, you and the Supplier will need to track this data differently in the manner prescribed by the Agreement. Please note that the agreement between you and the Supplier may also stipulate that, depending on the use of the Device and/or the software, different tariffs are applied to calculate the payment for the Resources consumed.

Advertising

3.6. We process the Data specified in clause 2.3 of the Policy also in order to send you advertisements of our goods and services via telephone, SMS messages, messages in mobile messengers, e-mail, via other communication channels.

3.7. We process this Data based on your consent, which you provide to us when registering your account on the Website.
You may revoke such consent at any time. You can revoke your consent here. For more information on revocation of consent to the processing of data, refer to clauses 6.11 – 6.14 of the Policy

3.8. If you refuse to provide us such Data for the purposes of sending advertising messages to you or withdraw your consent to its processing for such purpose, we will stop processing the Data for advertising purposes, which will not affect the validity of the Terms and Conditions, the Agreement, the functionality of the Website, the Mobile Application and the Software and will not affect your right to consume Resources and your duty to pay for them.

Our Legitimate Interest

3.9. We process the Data referred to in clauses 2.2.1, 2.2.3 – 2.2.4 of the Policy, as well as some technical information (which we do not use for your identification purposes) so that in the event of a legal dispute or an administrative check carried out concerning us, we can prove that we have fulfilled the requirements of Regulation No. 2016/679 of the European Parliament and of the Council of the European Union and other acts of the European Union that are binding for us, for example, have received your consent to process the Data or execute your inquiry/application.

3.10. 3.10. If you do not agree with the fact that we process this Data for the purposes specified in this clause of the Policy, you can reject their processing for such purposes. For more information about your right to object to the processing of Data, refer to clause 6.15 of the Policy.

Miscellaneous

3.11. If we need other Data or we have new goals for which we would like to process the Data, we will definitely inform you about it and, if necessary, ask for your permission to process such new Data or for such new purposes.

 4. How we process your data


Personal Data Processing Principles

4.1. We process your data in a lawful, fair, impartial and transparent manner.

4.2. We process personal data only by methods that are compatible with the objectives specified in Section 3 of the Policy. The categories and amount of personal data processed by us are the minimum necessary to achieve these goals. We do not process your personal data that is redundant in relation to the stated purposes of their processing, and upon receipt of such data without our consent (for example, at our email address), we delete it.

4.3. We ensure the accuracy and, if necessary, the relevance of personal data. In particular, we take reasonable measures to ensure the timely removal or correction of inaccurate data, taking into account the goals specified in Section 3 of the Policy. For more information about the refinement and addition of data, see clauses 6.5-6.8 of the Policy.

4.4. Your personal data will be stored in a form that allows to identify you. The storage period for your data is limited by the achievement of the processing objectives specified in Section 3 of the Policy. For more information about the storage period refer to Section 5 of the Policy.

4.5. Your personal data is processed in ways that ensure its appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction of data, using appropriate technical and organizational measures.

What Methods We Use to Process the Data?

4.6. Data processing shall mean any operation with it. These operations include: collecting, recording, organizing, structuring, storing, modifying and changing, retrieving, advising, using, disclosing, transmitting, distributing or otherwise providing, streamlining or combining, limiting, deleting or destroying. The content of these operations will vary depending on the nature of the relations between us. For example, the following processing methods are applicable to certain forms of relations with you or a third party:

4.6.1. If you only visit our website to examine information on it, then we collect data about you using cookies, store cookies on your device and use them to ensure the functioning of our Website – for more information, see Section 7 of the Policy. If you send us a message using the Website or the Mobile Application, we also receive directly from you the contact information and information about you in order to have the minimum necessary data to contact you and answer your questions – for these purposes we delete the Data, specified in clause 2.1 of the Policy, after the need to answer your question has disappeared or if you do not answer us within one month.

4.6.2. If you are a resident or owner of the premises where the Devices are used to keep records of the Resources consumed, then we process your data by collecting them (receiving them from you, the Supplier or independently using Devices) and storing them on our Company’s servers. The device readings we have stored for the purpose of fulfilling the contract with you or the Suppliers, as well as for the operation of the Website and the Mobile Application are organized, structured, and combined by us, and also retrieved and transmitted to you or the Supplier having access to your personal account on the Website (more about data transfer, see clause 4.10(a) of the Policy). Besides, we update our readings as we collect them from Devices, and also change or delete personal information about you if it turned out to be inaccurate or if, for example, the grounds for their processing disappear.

4.7. We do not make decisions regarding you based solely on the automated processing of your Data, and we do not assist the managing organization in making decisions in the same way. The final decisions related to the restriction of your access to the Resources and debt collection for their consumption are made by the person (the Supplier’s employee), who takes into account all the information actually available to him and based on it comes to a decision on the appropriateness of such measures.

4.8. We do not use your data for the formation of your profile (“profiling”). We do not use your Data by automatically processing it in order to evaluate your personal aspects, relating in particular to your economic situation, personal interests and preferences, behavior, etc.

4.9. We keep records of all activities related to the processing of your Data, saving them in electronic or written form. Such information is made available to supervisory authorities upon request.

Who We Transfer the Data to

4.10. We can transfer the Data to:

(a) the Suppliers who can access the Website via a personal account or the Mobile Application, and receive information about the amount of Resources consumed during a certain period of time, in order to calculate the fee for their consumption, invoice you and thus fulfill the Agreement.

(b) to Data-processing Companies, both those who are with us in one holding, and those that are not.

Such processing companies may execute certain data processing operations on our instructions (for example, store Data on their servers or help us encrypt them in order to protect the Data from unauthorized access). These processing companies will not be able to decide for themselves how to process your Data.

Processing companies may be located in countries outside the European Union, in particular, be located in the Russian Federation.

Transfer of Data to processing companies is necessary for us to fulfill the Agreement, provide you with uninterrupted access to the Website, Mobile Application and software, as well as to protect your Data and efficiently process it. Involvement of processing companies allows us to make access to the various functionalities of the Website, Mobile Application and software free or much cheaper than it is.

(c) To other companies or persons indicated by you, if you ask us to transfer your Data (for information on how to do this, refer to clauses 6.20-6.22 of the Policy).

(d) to a Representative so that he can fulfill his duties, in particular, to respond to your inquiries/applications.

(e) to Persons to whom the competent authority of your country, the European Union or an international authority will legally require us to transfer the Data, the requirements of which we will be required to comply with in accordance with the applicable law.

5. Data Storage and Protection


How Long We Keep Your Data

5.1. We will store the Data required for your registration in your personal account on the Website until the Terms and Conditions remain valid.

5.2. We will store the Data specified in clauses 2.1 – 2.2.2, 2.2.5 – 2.2.7 of the Policy as long as the Terms ad Conditions remain valid and, by virtue of their provisions, we process such Data using Devices, the Website, the Mobile Application and the software.

5.3. We will store the Data specified in clause 2.3 of the Policy, as well as cookies until you revoke your consent to the processing of such Data (you can withdraw your consent here, for more information about your right to revoke your consent, refer to clauses 6.11-6.14 of the Policy).

At the same time, we will continue to store such Data, if there is another reason for its processing (the Terms and Conditions or the Agreement), but in this case we will stop processing this Data for the purposes for which we received your consent.

5.4. We will keep the data that we received in the case specified in clause 2.1 of the Policy, until the moment when it is no longer necessary to answer your question or if you do not respond to us within one month.

5.5. Even if all the legal grounds for processing your Data specified in the Policy disappear (see Section 3 of the Policy), we will continue to store data that such legal grounds for processing your Data existed. This is necessary so that in the event of a legal dispute or an administrative review in our respect, we can prove that we have fulfilled the requirements of Regulation No. 2016/679 of the European Parliament and of the Council of the European Union and other acts of the European Union that are binding for us. For these purposes, we will store the Data referred to in clauses 2.2.1, 2.2.3 – 2.2.4 of the Policy until the expiry of the period within which the corresponding legal dispute or verification can be initiated.

Personal Data Security

5.6. Your personal data is stored in the territory of the European Union.

5.7. We take organizational and technical measures that guarantee and confirm the legality of the processing of your personal data, provide the necessary level of security of your data, commensurate with the risks associated with their processing. In addition, such measures are designed to ensure Data protection and accounting activities related to data processing. When developing such measures, we take into account, in particular, the likelihood of risk and danger to your rights, taking into account the nature, scope, characteristics and objectives of processing.

5.8. Organizational and technical measures that we take are reviewed by us on a timely and regular basis to ensure the security of your data.

5.9. Our employees, instructed on the security of personal data, as well as – in the case of the fulfillment of the Agreement – the employees of the Supplier, have authorized access to your data. In this case, we are talking about the data specified in clause 2.2 of the Policy, if it is processed to fulfill the agreement between such organization and you.

5.10. We are not responsible for the security of your data that you transfer directly to third parties, for example, via the websites of the Suppliers. You can contact them directly on issues regarding the protection of such transferred data. The exception to this rule are the cases when we receive such personal data from the Suppliers.

Informing about Personal Data Incidents

5.11. We will immediately notify you about the leakage of your Data, if based on the assessment such leakage leads to a high degree of risk to your rights and freedoms. Leakage means one of the following possible situations:

5.11.1. Personal Data Infringement – when data is disclosed or accessed as a result of a random event or unauthorized actions.

5.11.2. Data Integrity Violation – when personal data can be changed inadvertently or without authorization.

5.11.3 Data Violation – when personal data can be destroyed in unauthorized manner or accidentally (or access to them becomes impossible).

5.12. We will independently choose a way of informing you about Data leakage. If it is possible and does not require disproportionate efforts, then we will inform you about the leakage, at least via two communication channels. Specific communication channels will be selected based on the availability, accuracy and relevance of your contact information. Such communication channels may include the following:

5.12.1. Sending a message by e-mail.

5.12.2. Posting a message in your personal account on the Website.

5.12.3. Mobile communication: informing using a call, sending a short text message (SMS) or an instant messaging service (messenger).

5.13. We will take all possible and appropriate measures to inform you as soon as possible. Information about the leakage will be provided within at least 72 hours, if it is at all possible.

5.14.We may not notify you about a leakage if:

5.14.1. We applied such organizational and technical measures to the Data that a person who does not have legal access to it cannot understand its content. For example, we encrypted the Data.

5.14.2. We took timely additional measures to ensure that there is no high degree of risk to your rights and freedoms.

5.14.3. Informing you along with other personal data subjects requires disproportionate efforts. In this case, we will publish information about the leakage in such manner that the information about the leakage will reach the maximum possible number of users. This means that, at least, we will post such message on a website using a banner on the main page or in users’ personal accounts.

 6.0. Your Rights and the Procedure for Their Implementation


How to Learn about the Processing of Your Data by Us?

6.1. 6.1.You have the right to know if we process your Data, and if so, then:

(a)  what Data we process;

(b)  from whom we received the Data (if we did not receive it from you);

(c)  for what purposes we process the Data;

(d)  to whom we transfer the Data;

(e)  if we transfer the data to countries outside the European Union or to international organizations, what guarantees are provided by us in such case (if we are obliged to provide such guarantees);

(f)  if there is a right to require us to delete, correct, or limit the processing of the Data;

(h) whether decisions concerning your are made based solely on automated Data processing, and if so, in what way, what significance such decisions have and what consequences they entail for you.

For more information on how to make such inquiry, during what period of time we will execute such inquiry and notify you about it, and in what cases we will deny your inquiry, please, refer to clauses 6.246.32 of the Policy.

 How to Get a Copy of the Data?

6.2. You have the right to request from us a copy of the Data processed in relation to you in electronic form or on paper.

6.3. Form of the copy: if you send your request to us in electronic form, then, unless you specify otherwise in your request, we will provide you with a copy of the Data we process also in electronic form. In other cases, a copy of the Data will be provided to you on paper.

6.4. Fee for providing a copy of the Data: electronic copies of the Data are provided free of charge. The first copy of the Data on paper is provided to you free of charge, and each next copy is provided under the condition that you pay a reasonable fee to offset our costs of preparing and sending such copy to you.

For more information on how to make a request to obtain the copy of the Data, during what period of time we will execute such request and notify you about it, and in what cases we will deny your request, please, refer to clauses 6.246.32 of the Policy.

 How to Clarify/Supplement Data?

6.5. You have the right to request that we change the inaccurate Data processed in relation to you or to supplement the Data.

6.6. If the additional Data is not covered by the purposes for which we previously processed your Data, we will not process such additional Data until we receive your consent to process it for such new purposes.

6.7. Since we do not verify the accuracy of the Data transmitted to us by you or the Suppliers, you must personally insure its reliability and bear the risks of the reverse, in particular, due to the unreliability of the Data provided to us, we will not be able to fulfill the Agreement, and the Supplier will not be able to fulfill the Contract using Devices, Software, Website and Mobile Application.

6.8. When you clarify the Data, we will take steps to inform other recipients about it and inform you about such recipients, if you request such information.

For more information on how to send an application to clarify or supplement the Data, during what period of time we will satisfy such application and inform you about it, and in what cases we will deny it, please refer to clauses 6.246.32 of the Policy.

How to Delete Data?

6.9. You have the right to ask us to delete the Data if you:

6.9.1. You believe that the Data is no longer required for the purposes for which we received it.
Please, note that the deletion of the Data necessary for the compliance with the Terms and Conditions is possible only with the simultaneous termination of the Terms and Conditions in the part in which it provides for the processing of the deleted Data using the Software, the Website and the Mobile Application.
In this regard, we will consider your request for deletion of such Data at the same time with your refusal from the services provided to you by us for its processing using software, the Website and the Mobile Application, and, therefore, your refusal of the Terms and Conditions in this part. Such refusal does not exclude your right to consume Resources and your obligation to pay for them, however, neither you nor the Supplier can use the Software, Mobile application and personal account on the Website to track the amount of resources you use – in this case, you and the Supplier will need to track this data by a different method stipulated by the Contract. Please note that the agreement between you and the Supplier may also stipulate that, depending on the use of the software, different tariffs are applied to calculate the payment for the Resources consumed.

6.9.2. Have withdrawn your consent to the processing of the data specified in clause 2.2.3 of the Policy, as well as cookies (see details in clauses 6.11 – 6.14 of the Policy), if such Data was processed only on the basis of your consent.

6.9.3. You think that we process the Data illegally.

6.10. Please, note that if you demand that we remove any references, copies or exact repetitions of the Data, we will take measures to inform about this other data-processing controllers and, in particular, the Supplier.

For more information on how to send an application to delete the Data, during what period of time we will satisfy such application and inform you about it, and in what cases we will deny it, please refer to clauses 6.246.32 of the Policy.

How to Revoke the Consent to Data Processing?

6.11. You may at any time revoke your consent to the processing of the data, specified in clause 2.2.3 of the Data Policy, as well as the cookies (or other Data that we process on the basis of your consent).

6.12. You can revoke your consent to the processing of data here.

6.13. If your consent was the sole basis for processing such Data, we will delete it.

6.14. If, in addition to your consent, there is another reason to process your Data (the need to comply with the Terms and Conditions and/or fulfill the Contract / our legitimate interest), we will not delete such Data, but stop processing it for the purposes for which we received your consent, of which we will inform you separately.

How to Object to Data Processing?

6.15. You have the right to object to the processing of your Data:

6.15.1. For the purposes specified in clause 3.9 of the Policy (in order to secure our legitimate interest).
If we receive such objection, we will stop processing such Data and delete it, unless we have valid legal grounds for processing such Data that prevails over your interests, rights and freedoms, or when such processing is necessary to substantiate, execute or maintain defense in lawsuits.
Until the fact is established whether our legal grounds for processing the Data prevail over your interests, rights and freedoms, we will restrict the processing of the Data (more information on the consequences of limiting the processing, see clauses 6.16-6.19 of the Policy).

6.15.2. For direct marketing purposes.
If we receive such objection, we will not delete your Data, but will stop processing it for direct marketing purposes.

For more information on how to send an application to limit the processing of the Data, during what period of time we will satisfy such application and inform you about it, and in what case we will deny it, please refer to clauses 6.246.31 of the Policy.

How to Limit Data Processing?

6.16. You have the right to ask us to limit processing of the Data in cases when:

6.16.1. You dispute the accuracy of the Data we process.
In this case, we will limit the processing of the Data for the period necessary for us to confirm the accuracy of such Data.

6.16.2. The processing of your Data by us is illegal, but you do not want us to delete the Data.
In this case, we will limit the processing for the period you specify, or until you ask us to delete the Data, or until we have a different legal basis for processing it.

6.16.3. We no longer require the Data in order to process it, but you need it to protect your rights in court.
In this case, we will limit the processing for the period you specify, which is required for you to participate in such dispute, either until you ask us to delete the Data, or until we have a different legal basis for processing it.

6.16.4. In the case specified in clause 6.15.1 of the Policy.

6.17. If you have limited the processing of Data by us, we will not delete it, but we will not be able to process the Data (except for storage) without your consent, unless such processing is required:

(а) to protect our interests in court;

(b) to protect the rights of another individual or a legal entity;

(d) for reasons of public interest of the EU or a member state of the European Union.

6.18. Please, note that restricting the processing of the Data by us required for the compliance with the Terms and Conditions and/or fulfilling the Agreement may lead to the impossibility of compliance with the Terms and Conditions, as well as the impossibility to fulfill the Agreement using Devices, the Website and the software. This does not influence your right to consume the resources and your obligation to pay for them, however, neither you nor the Supplier can use the Software and a personal account on the Website to track the amount of resources you use – in this case, you and the Supplier will need to track this data by a different method stipulated by the Contract. Please note that the agreement between you and the Supplier may also stipulate that, depending on the use/failure to use the Device and/or the software, different tariffs are applied to calculate the payment for the Resources consumed.

6.19. When we receive your request to limit the processing of the Data, we will take steps to inform other recipients about it and inform you about such recipients, if you request such information.

For more information on how to send an application to limit the processing of the Data, during what period of time we will satisfy such application and inform you about it, and in what case we will deny it, please refer to clauses 6.246.31 of the Policy.

How to Transfer the Data Concerning You (to You or Another Controller)?

6.20. You are entitled to receive the Data relating to you that you have provided to us in a structured, universal and machine-readable format, and transfer it to another controller without any hindrances on our part.

6.21. If this is technically feasible, then upon your request we will transfer such Data to another controller directly. To exercise this right, you should inform us about the specific data you have previously submitted to us, which you would like to transfer to a new controller, and specify such new controller.

6.22. Please, note that:

(a) This section only deals with the Data that you have provided to us;
This means that we are not obliged to provide you or transfer to another controller the data that has been transmitted to us by other persons, as well as the data that we have received ourselves as a result of processing the data provided by you, in a structured, universal and machine-readable format. However, this does not limit you in the right to receive information about the processing of such Data and its copy according to the procedure specified in clauses 6.1 – 6.2 of the Policy.

(b) Data transfer according to the procedure specified in this section to another controller does not influence its processing by us. To stop data processing by us, you can separately request that we delete the Data (clauses 6.9-6.10 of the Policy), object to its processing (clause 6.15 of the Policy) or restrict data processing (clauses 6.16-6.19 of the Policy).

For more information on how to send an application on the Data transfer, during what period of time we will satisfy such application and inform you about it, and in what cases we will deny it, please refer to clauses 6.246.31 of the Policy.

Where to Appeal for Our Actions / Omissions?

6.23. If you believe that our actions or omissions violate your rights, freedoms and interests, you can appeal to the supervisory authority in charge of the monitoring of the implementation of Regulation No. 2016/679 of the European Parliament and the Council of the European Union in your country.

How to Send Us an Inquiry / an Application?

6.24. To send us an inquiry for information on data processing (clause 6.1 of the Policy), a request for providing a copy of the Data (clauses 6.2-6.4 of the Policy), an application for updating/supplementing the Data (clauses 6.5-6.8 of the Policy), an application for Data deleting (clauses 6.9-6.10 of the Policy), revoke consent for Data processing (clauses 6.11-6.14 of the Policy), send us an objection to the Data processing (clause 6.15 of the Policy), an application on the restriction of data processing (clauses 6.16-6.19 of the Policy), an application on the transfer of the Data relating to you that you have provided to us, to you or other controller (clauses 6.20-6.22 of the Policy), you can:

6.24.1. Fill out and send us a message using the feedback form in your account on the Website, choosing the option you need from the list of headings.
In this case, in order to protect your Data from unauthorized actions and make sure that you, and not someone else, sends us an inquiry/application, we may ask you to re-enter your username and password from your personal account when you send the corresponding inquiry/application.

6.24.2. Send us an email to privacy@waviot.com, describing the essence of your inquiry/application and desire for it to be fulfilled.
In this case, to protect your Data from unauthorized actions and make sure that it is you, and not someone else, who sends us an inquiry/application, we can ask you for additional information to identify your identity, in particular, to contact you by phone, confirm the fact of sending us an email and ask for the code word. In this case, we will record the telephone conversation.

6.24.3. Contact us or the Representative by phone, and state to our employee or Representative the essence of your inquiry/application and desire for it to be fulfilled.
In this case, to protect your Data from unauthorized actions and make sure that it is you, and not someone else, who sends us an inquiry/application, we or our Representative can ask you to tell the code word that you have told us when registering your account. In this case, we will record the telephone conversation.

6.24.4. Send us a letter on paper to our postal address, describing in it the essence of your inquiry/application and desire for it to be fulfilled.
In this case, to protect your Data from unauthorized actions and make sure that it is you, and not someone else, who sends us an inquiry/application, we or our Representative can ask you for additional information to identify your identity, in particular, we can contact you by phone, confirm the fact of sending us an email and ask you to tell the code word. In this case, we will record the telephone conversation.

6.24.5. Personally come to our office and describe to us or our Representative the essence of your inquiry/application and desire for it to be fulfilled.
In this case, to protect your Data from unauthorized actions and make sure that it is you, and not someone else, who sends us an inquiry/application, we or our Representative can ask you for additional information to identify your identity, in particular, ask you to present a document verifying your identity and ask you to tell the code word.

When Will We Respond to Your Inquiry/Application?

6.25. We will take all measures to fulfill your inquiry/application as quickly as possible.

6.26. We will inform you about the results of the execution or refusal to fulfill your inquiry/application no later than one month from the date of receipt of your inquiry/application.

6.27. If necessary, in the event of the complexity of your inquiry/application or, when we receive several inquiries/applications from you, we can extend the time period for the execution of your inquiry/application for additional two months. We will notify you of this extension and its reasons no later than one month from the date of receipt of your inquiry/application.

6.28. If in one month we have not fulfilled your inquiry/application or have not informed about the extension of its execution period and the reasons for such extension, and if we have not executed your inquiry during the extended period, you can appeal our actions (omission) to the supervisory authority responsible for monitoring the application of Regulation 2016/679 of the European Parliament and of the Council of the European Union in your country.

How Will We Respond to Your Inquiry?

6.29. If you submit an inquiry in electronic form (via a feedback form or via e-mail), then, if possible, we will also send you the requested information and the report on the execution/rejection to execute your inquiry/application in electronic form, if you did not ask us to answer you in some other way in your inquiry/application.

6.30. You can ask us to respond to your inquiry/application verbally. In this case, we will provide you with information in response to your inquiry/application verbally, if we have established your identity during such verbal inquiry. To establish your identity during a telephone conversation, we use the code word that you need to tell to our employee or Representative during a telephone conversation in response to a question from the latter. In this case, we will record a telephone conversation during which you requested information, and we identified you and provided you with the necessary information. When you contact one of our offices or the office of our Representative in person, we or the Representative will establish your identity by checking the document certifying your identity, or by asking you to tell the code word.

6.31. In other cases, we will respond to you in writing.

When Will We Reject Your Inquiry/Application?

6.32. We will reject your inquiry/application if:

6.32.1. You have sent an inquiry/application in a situation where you are not entitled to claim its satisfaction (for example, you have requested information from us, which we are not obliged to provide to you).

6.32.2. We cannot establish your identity, and the additional ways of identifying you (in particular, requesting additional information from you) do not prove successful.

6.32.3. Your inquiries/applications are clearly unfounded or are excessive, in particular due to numerous repetitions. In this case, instead of rejecting your inquiries/applications, we can charge a reasonable fee for their execution.

  7.0. Cookies Processing Policy


7.1. Cookie-files (or “cookies”) are the technical files stored on your device by websites that you have visited, including our Website. On subsequent or repeated visits to the Website, the cookies are automatically re-sent to the Website to ensure its efficient and uninterrupted operation, as well as to ensure its usability. Deleting or blocking the cookies may disrupt the functionality of the Website or its individual elements, including making them unavailable.

7.2. Cookie management is possible via your browser: You can view or block them, but in the latter cases you should take into account possible negative consequences. In addition to the mentioned partial inoperability of the Website, you should take into account the risk of exiting from your personal account, deleting saved forms or resetting your settings. Besides, refusal to receive cookies by itself implies the need to save a cookie on your device.

7.3. You can read how to manage cookies in different browser versions using the following links:

7.3.1. Internet Explorer;

7.3.2. Mozilla Firefox;

7.3.3. Google Chrome;

7.3.4. Apple Safari;

7.3.5. Opera.

If your browser is not listed above, then you can find the corresponding information using the following websites:

7.3.6. http://www.aboutcookies.org/;

7.3.7. http://www.cookiecentral.com/faq/

7.4. Cookies used by us, according to their functionality, can perform the following roles:

7.4.1.  They ensure the operation of the Website, in particular, they are used when forms on the Website are filled in, or provide navigation when working with the Website.

7.4.2.  They provide a count of visitors and traffic sources of the Website, allow to determine the popularity of different pages of the Website. Such cookies contain anonymous information.

7.4.3.  They are used for targeting advertising for you, including on other websites.

7.4.4.  They are used for the Jivochat service, which provides communication with users, in connection with which they need to provide their personal data, phone number and mail address.
For more information on the use of cookies by the Jivochat service and its use management options see the corresponding policy. Unless otherwise specified, the processing of data collected by cookies is regulated by the corresponding Data Use Policy.

7.5. The site uses third-party cookies. The following are the providers that provide such files used to collect impersonal browsing history. If you want to decline the use of such cookies or get more information, you can use the links below:

7.5.1.  Google Analytics

7.5.2.  Google AdWords and Google Remarketing

7.5.3.  YouTube

7.5.4.  Yandex.Metrica