Privacy policy

This Privacy Policy (hereinafter – “Policy”) describes how we collect, use, process, store and disclose Your information, including personal data. The Policy applies to all and any information, including personal data, collected by Us from You, when You register on Trassir Website, order Trassir products and use Trassir services on the Website.

1.   Basic terms

1.  We/Us/Our/Data controller – company DSSL LLC, registered at: 105082, Russia, Moscow, ul. Bakuninskaya, d. 71, et. 6, komnata 7;

2.   Website – website located at the Internet address https://trassir.com/ and its subdomains;

3.   Products and Services – goods, services, rights to use software, which are offered and may be purchased on the Website;

4.   You/User – any person who has access to the Website via the Internet and is registered on the Website and uses the Website and purchases Products and Services.

User is any capable individual who has reached the age of 18 and is using the Website for his own interests or an individual authorized to represent a legal entity;

5.   Personal data – any data that can identify you as an individual for example name, address and contact information;

6. Registration – filling of a registration form on the Website by entering data, which may include personal data;

7.   Processing of personal data – any action (operation) or a set of actions (operations) performed with or without the use of automation with personal data, including collection, recording, accumulation, storage, clarification (update, change) extraction, use, transfer (distribution, provision of access), depersonalization, blocking, deletion, destruction of personal data;

8.   Cookies — a small piece of information sent by a web server and stored on the User's computer that the web client or a web browser sends every time to web server in the HTTP-request when User tries to open the relevant page of the Website.

2.   What data, for what purposes, based on what grounds, and how long we process the data

Data

Purpose

Legal ground

Storage period

Information we get directly from you


Name, contact number, email

To offer access to a demo of the product or service


Contract

2 months after the last interaction


Data in messages sent by you, email address

To request customer's feedback on the provision of demo/products and/or services


Consent


as long as it is necessary for the purpose for which it was originally obtained


Name, location, company name, email, phone number

To provide information about our partner program options

Consent


Visitor behaviour information, cookies


To optimize customer experience by improving our knowledge of our customers


 Legitimate interest to improve the quality of our goods and services



Data related to the device/browser, cookies, IP address and on-site activities

To provide the most user-friendly online navigation experience


Legitimate interest to improve the quality of our goods and services



IP address, technical information regarding interaction with website services, Internet log information

To protect our website against unauthorized access


Legitimate interest to improve the quality of our goods and services


for the period while you use the website


Name, email, information about consent to receive marketing information, interaction with mailing (opening, clicks)

To send promotional information regarding products and/or services

Consent


Information about consents/withdrawals of consents, rejections

To ensure compliance with GDPR

Legal obligation

as long as it's required by law


Any information

To prevent violation of and to supervise compliance with laws and regulations


Legal obligation

as long as it's required by law




4.   Where did we get your data from?

1. Browser

Your internet browser (such as Mozilla Firefox, Google Chrome, or Microsoft Internet Explorer) automatically transmits some information to us every time you access content on one of our internet domains. Examples of such information include the URL of the particular Web page you visited, the IP (Internet Protocol) address of the computer you are using, or the browser version that you are using to access the website.


2. Business partners

We collect personal data from our business partners in connection with identifying prospective customers, conducting marketing activities, coordinating events and programs, etc.


3. Directly from you

We may obtain personal data directly from you.



5. Conditions of storage, processing and disclosure of information and data

1. We shall keep information and data received from You in strict confidence and undertake all necessary legal, organizational and technical measures to protect such information from unauthorized or accidental access, destruction, modification, blocking, copying, supply, distribution and other illegal actions in relation to such information and personal data. We shall undertake to take all measures to prevent the disclosure or use of such information and data, except as expressly stated in this Policy.

2. Your information and personal data shall be kept in confidence, except for cases of voluntary provision of such information for general access to the public. We are guided by applicable law in the processing of information and personal data.

3. Access to Your information, including personal data, shall be granted only to our employees, consultants and auditors, which require access to such information for the performance of their duties, in compliance with the necessary measures to protect the confidentiality of such information.

4. We may disclose information and data provided by You to third parties in the following cases:

  • to our subsidiaries and affiliates, if it is required in order to provide Products and Services;

  • to contractors, service providers, and other third parties performing services for us and on out behalf and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. These partners process your data at and according to our instructions only as necessary to provide the requested services such as delivery, hosting, CRM solution provision, analytics and fraud prevention;

  • if such disclosure is necessary for the administration of justice, enforcement of judgment, the act of another body or official to be executed in accordance with applicable legislation;

  • You consented to such action;

  • to ensure protection of our rights and legitimate interests.

5.   Obtaining and use of personal information and data received from minors

1. Our company, acting in good faith, does not accept and shall not intentionally collect any information and data on persons under the age set by the laws of their country of residence (location) required to use products and services similar to our Products and Services, including surname, name, address, telephone number and/or email.

2. Persons under the abovementioned age cannot provide their information and data without the required consent of parents or other legal representatives.

6.   Your Rights

You may exercise any of the rights described in this section by sending an email to welcome@trassir.com, e.makarevich@dssl.ru. Please note that we may ask you to verify your identity before taking further action on your request.

6.1 Information about the processing of your personal data

6.2 Obtain access and manage your information

Users may access and update some of information through request to Us.

6.3 Ask for incorrect, inaccurate or incomplete personal data to be corrected

You have the right to ask us to correct inaccurate or incomplete personal information.

6.4 Receive your personal data in a machine-readable format and send them to another controller (data portability)

You may request copies of your personal information held by us. You may also request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

6.4 Request that personal data be erased when they are no longer needed or if processing is unlawful (right to be forgotten)

We generally retain your personal information for as long as is necessary for the performance of the contract between You and Us and to comply with our legal obligations. If you no longer want Us to use your information to provide Products and Services to You, You can request that we erase your personal information. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers. The right is not absolute and only applies in certain circumstances.


6.5 Withdraw consent and restrict processing


Where You have provided your consent to the processing of your personal information by Our company you may withdraw your consent at any time by sending a notice to Us specifying which consent you are withdrawing. This means that an individual can limit the way that an organization uses their data. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Company override your own.

This is an alternative to requesting the erasure of their data.

6.6 Objection to processing (including for marketing purposes)

You may require Us not to process your personal information for certain specific purposes (including profiling). If you object to such processing We will no longer process your personal information for these purposes unless We can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask Us to cease processing your data for these direct marketing purposes by sending an e-mail to welcome@trassir.com, e.makarevich@dssl.ru.

6.7. Lodge a complaint with a supervisory authority

In accordance with Art. 77 GDPR, you, as a data subject, have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or where an alleged infringement of the GDPR has taken place.

7. International data transfers

Our Services is global by nature and your data can therefore be transferred to third parties in other countries, at that we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection. Laws in these countries may differ from the laws applicable to your country of residence.

8. Third Party Websites

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third party operating any site to which the Website contain a link. The inclusion of a link to another site on the Website does not imply endorsement of the linked site by Us.

9. Contacts

If You have any questions or complaints about this Privacy Policy, you may contact us at: welcome@trassir.com, e.makarevich@dssl.ru.

10. Changes to the Policy and applicable law

1.      The Company reserves the right to change this policy at any time. If you disagree with the revised Privacy Policy, you may cancel your account. If you do not cancel your account before the date the revised Privacy Policy becomes effective, your continued access or use of our Website, purchase of Products and Services will constitute acceptance of the revised Privacy Policy.

2.      This Policy and the relationship between You and Us arising from the application of the Privacy Policy shall be subject to the applicable legislation.

Effective date: December 27th, 2021.