Privacy Policy

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By checking the “I Agree” box accompanied by a link to this Policy, you (also referred to as “User”) freely, willingly, and in your own interest give your written consent to the processing of Personal Information as and when set forth in this Policy.

General provisions

This Policy constitutes an integral part of the User Agreement (“Agreement”) posted and/or available on the SigHF website and other agreements entered into with the User where expressly provided for in such agreements. Therefore, by entering into the Agreement and the said agreements in the manner set out therein, including the use of the Application, you accept the terms of this Policy in its entirety.

The manner in which Personal Information is processed includes any action (or combination of actions (or operations), including, but not limited to, collection, recording, systematization, storage, clarification (updating, modification), extraction, use, transfer (provision, access), anonymization, blocking, deletion, destruction for purposes set forth in this Policy, with or without the use of automated means at SigHF’s sole discretion.

Hereinafter in this Policy the terms and definitions provided for in the Agreement and other agreements entered into with the User are used, unless otherwise stipulated in this Policy or arising from its essence. Otherwise, the term used in this Policy shall be interpreted in accordance with applicable law, customary business practice, or scientific doctrine.

Personal Information

Personal Information in this Policy means:

  • Information that the User provides about himself/herself upon registration or authorization, as well as in the process of further use of the Application and/or the Service, including the User’s personal data.
  • Data that is transmitted automatically depending on the settings of the User’s software in an impersonal form.
  • SigHF reserves the right to set requirements for the composition of the User’s Personal Information that must be provided in order to use the Application and the Service based on it. If certain information is not marked as mandatory by SigHF, such information will be provided or disclosed by User at his or her own discretion.
  • When registering, User must provide an account name (login), email address and password.
  • When registering SigHF creates a unique User ID (user_id) for each User. User_id is tied to User’s profile information.
  • In order to conclude the Contracts the User may also provide the following personal information about him/herself: name, title and phone number.
  • If an individual acts for an organization, the name, TIN, KPP, OGRN, registration address and postal address of such organization, corporate telephone number, settlement account, name of the servicing bank, its BIK and correspondent account may be provided in addition. The specified information about the organization does not relate to personal data.
  • If an individual acts as an individual entrepreneur or in his interests, at the request or with the direct written consent of such an individual entrepreneur, respectively, the following may be provided in addition: full name and initials of the individual entrepreneur, TIN, OGRNIP, and address for correspondence, telephone number, settlement account, the name of the servicing bank, its BIK and correspondent account.
  • Data disclosed by the User to an unspecified circle of people. Using the functionality of the Application, the User may independently, by their own actions, at their own discretion, disclose to an unspecified circle of people (publish in the Application) the information of their profile in the Application, which may include personal data, including: full name, first name, middle name, gender, date of birth, city of location, place of work, position, information about themselves in a free form. Information added by User to his profile becomes available to an unlimited number of people, subject to the profile information display settings in the Service.
  • SigHF does not perform any checks on the accuracy of the Personal Information provided and on the User’s consent to its processing in accordance with this Policy, believing that the User acts in good faith, with circumspection and makes all reasonable efforts to keep such information up to date and to obtain all necessary consents from the subjects of Personal Information.
  • SigHF collects and stores data about User’s activities on the Service using log files. In the case of actions performed by an authorized User, such information is linked to the User’s ID.

The User acknowledges and accepts the possibility of using third party software on the Site and in the Mobile application, as a result of which such parties may receive and transmit the data specified in clause 2.1.2 in an impersonal form.

Within the framework of provision of certain Services SigHF may provide Users with the possibility to place on their own personal pages of the Site an impersonal data collection and processing software similar to that described in paragraph 2.7. of this Policy, whereby such Users may receive the data referred to in paragraph 2.1.2 in an impersonal form. The composition and terms of the collection of anonymized data in such case shall be determined by the User who has placed the software used to collect and process the anonymized data, but may not be in conflict with this Policy.

SigHF is not responsible for the way in which the User’s Personal Information is used by third parties with whom the User interacts as part of the use of the Application and/or the Service.

Legal basis for the processing of Personal Information

The legal basis on which SigHF uses Personal Information includes:

  • Processing of Personal Information when the User has provided consent to the processing for one or more specific purposes;
  • Processing of Personal Information when it is necessary for the performance of a contract to which the User is a party;
  • Processing of Personal Information when it is necessary for the conclusion of a contract with the User;
  • Processing of Personal Information as necessary in order for SigHF to fulfil its obligations under applicable law.

Children Policy

SigHF does not knowingly collect Personal Information from children under the age of 18, nor does it solicit or allow them to use the Application. Individuals under the age of 18 are not permitted to provide personal information including name, address, telephone number and email address. If SigHF becomes aware that information has been obtained from a child under the age of 18, SigHF will promptly delete such information. If you believe that we may have received any information from or about a child under the age of 18, please contact us at [email protected].

Purposes of Processing Personal Information

SigHF processes, including collecting and storing the Personal Information needed for the conclusion and execution of contracts with the User and made publicly available by the User by filling out their profile and setting the settings in the Personal Area.

SigHF may use the Personal Information for the following purposes:

  • Entering into contracts to use the Application and the Service; Contracts are entered into remotely through the exchange of electronic documents, which are signed with a simple electronic signature. In this case, the role of the User’s simple electronic signature key can be a pair of login – password or their email address. That’s why they are requested when registering.
  • Performance of obligations under the concluded contracts, including providing the User access to the Application and the Service; Applications for the provision of access to the Service are accepted using the software tools of the Application and email. As part of the functionality of the Service, the Rights Holder shall store, systematize and display the User profiles containing Personal Information in the Application.
  • Identification of the User within the framework of performance of the obligations under the agreements concluded with the User; the User’s Personal Account is linked to the User’s login-password and email address.
  • Providing technical support in connection with the use of the Application and the Service; Requests to the support service are accepted using the software tools of the Application and e-mail.
  • Providing communication with the User for the purpose of information service and improving the quality of the Service under the signed Agreements, including in the order of notification with the involvement of third parties; Communication with the User is carried out through e-mail or by subscriber phone number specified by the User during registration or during the use of the Application and/or the Service.
  • Using impersonal data for targeting advertising and/or informational materials by age, gender, other characteristics.
  • Conducting marketing, statistical and other research on the basis of anonymized data. The data from the data collection systems specified in clause 2.7. in impersonal form shall be collected and analyzed in order to find out how much time Users spend in different sections of the Application, their interests and preferences.

Compliance with legal requirements.

  • SigHF, as organizer of the dissemination of information on the Internet, stores information concerning the receipt, transmission, delivery and/or processing of written text, images, sounds, video or other electronic communications of Internet users and information concerning those users for a period of one year from the end of such activities.

User rights with respect to Personal information

If provided by applicable law, the User has the right:

  • To receive information about the collection and use of their personal data.
  • To gain access to his personal data and to correct it if it is incorrect or incomplete.
  • Refuse to process his/her personal data if its accuracy is disputed, the processing is unlawful, and in cases where SigHF no longer requires the personal data for the purposes for which it was processed by SigHF.
  • To object to the processing of his/her personal data or to prohibit its processing if SigHF has processed it for the performance of tasks in the public interest or in its own legitimate interests and it is not necessary to continue such processing.
  • To withdraw at any time the consent the User has given to the processing of his/her personal data. If the User withdraws its consent to the processing of personal data, such withdrawal will not affect the lawfulness of the processing that SigHF carried out on the basis of such consent prior to its withdrawal.
  • Request the deletion of his/her personal data: when it is no longer relevant for the purposes for which it was collected or processed; when the consent has been withdrawn and SigHF has no grounds for further processing; when there are objections to further processing in the public interest or in SigHF’s own legitimate interests and there is no compelling need for such processing to continue; when personal data have been processed unlawfully.
  • Not to be subject to a decision based solely on automated processing, including profiling, which creates legal consequences for the User or affects the User in other similar ways, unless there is a legal basis for continuing the processing.
  • To obtain personal data in a structured, commonly used, and machine-readable form, in order to be able to transfer the data, in cases where SigHF processes the personal data provided by automated means.
  • These rights can be exercised by using the tools provided by SigHF in the Appendix or by making a specific request to SigHF in the ways described below. SigHF will respond to any such requests in a timely manner in accordance with applicable law. In some cases, SigHF may ask User to go through an identification process before processing the request. User shall have the right to contact the relevant supervisory authority in their jurisdiction if SigHF’s response is not satisfactory to them.

Retention of Personal Information

All Personal Information collected will be retained only for the period necessary to fulfill the purposes for which such information was collected or for the period permitted or required by the provisions of applicable law. From time to time, SigHF conducts a review of its data processing systems to determine whether the purposes for which users’ personal information is collected and processed remain valid. This determination is based on a number of factors which include but are not limited to the following: whether User maintains a relationship with SigHF; whether SigHF has fulfilled User’s requests (including any additional tasks); whether a contractual relationship exists between User and SigHF; and whether there are contractual or legal grounds for continuing to hold User’s Personal Data. SigHF will update its systems based on the results of such checks and notices received from User.

In order to improve the quality of the Service and to enable legal protection, SigHF may retain log files of actions taken by the User within the framework of using the Application and/or the Service as well as in connection with the conclusion and performance of the Agreement and other contracts by the User, for a period of 1 (One) year from the date of their execution.

Requirements for the Protection of Personal Information

SigHF will store Personal Information and protect it from unauthorized access and dissemination in accordance with its internal rules and regulations.

Personal information will be kept confidential, except for information disclosed by the User to the general public (Section 2.4 of this policy) and in other cases where the technology of the Application or the Service or the settings of the software used by the User allow for an open exchange of information with other users of the Application or any other users of the Internet.

Transmission of Personal Information

  • SigHF may share the Personal Information with third parties in the following cases:
  • User has expressed his or her consent to such actions, including when User applies settings to the software used that do not restrict the provision of certain information;
  • The transfer is necessary as part of the User’s use of the functionality of the Application and/or the specifics of the Service based on it;
  • In connection with the transfer of the Application to the possession, use or ownership of such third party, including the assignment of rights under contracts concluded with the User in favor of such third party;
  • At the request of a court or other authorized governmental authority within the scope of the statutory procedure;
  • To protect the rights and lawful interests of SigHF in connection with breach of contracts with the User.

Modification and deletion of Personal Information

  • User has the right to edit at any time in their myAlpari the Personal Information they provided at the time of registration or authorization.
  • User may delete his account or exercise his right to withdraw his consent to the processing of his Personal Information by sending a request to SigHF to delete his account at [email protected].

Changes to this Privacy Policy

This Policy may be changed or terminated unilaterally by SigHF without prior notice to User. The revised Policy shall be effective upon posting on the SigHF Site, unless otherwise provided for in the revised Policy.