Privacy Policy

This Privacy Policy (“Policy”) is intended to describe in detail our approach to the processing of personal data that we collect and process in the course of your use of our website relocationcompass.com (the “Website”). In processing your personal data in connection with your use of the Website, relocationcompass acts as a personal data controller (as defined below) and is subject to the requirements of data protection and personal data protection laws and regulations.

1 TERMS USED

Below you will find explanations of some terms used in the Policy.

Personal data operator – a legal entity, independently or jointly with other persons, organizing and (or) carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data.

Personal data is any information relating directly or indirectly to a certain or definable natural person (subject of personal data). The subject of personal data is you, the user of the Website.

Confidentiality of personal data – a requirement obligatory for observance by Relocation Compass and other persons who have access to personal data, not to disclose to third parties and not to disseminate personal data without the consent of the subject of personal data or other grounds established by law.

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

Non-automated processing of personal data – any actions with personal data, provided that the use, clarification, distribution and destruction of personal data are carried out with the direct participation of a person.

Automated processing of personal data – processing of personal data by means of computer equipment.

Destruction of personal data – actions as a result of which it becomes impossible to restore the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed.
Cross-border transfer of personal data – transfer of personal data to the territory of a foreign country to a foreign government authority, a foreign individual or a foreign legal entity.

Depersonalization of personal data – actions, as a result of which it becomes impossible to determine the belonging of personal data to a particular subject of personal data without using additional information.

Blocking of personal data – temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data). Personal data information system – a set of personal data contained in databases and information technologies and technical means ensuring their processing.

Special categories of personal data – data relating to race, nationality, political opinions, religious or philosophical beliefs, health status and intimate life.

Biometric personal data – data characterizing physiological and biological features of a person, on the basis of which it is possible to establish his/her identity and which are used by the Operator to establish the identity of the personal data subject.

2 WHAT CATEGORIES OF PERSONAL DATA WE PROCESS AND FOR WHAT PURPOSES

You may use our Website to explore the information it contains about relocationcompass, our areas of activity, the services we offer to our clients. On our Website you can also find the latest news, newsletters and digests on changes and trends in legislation and law enforcement practice. You can do all of this without providing us with any information about yourself and we will not process your personal data, except for information collected automatically (as described in Section 4 of this Policy). We will also not process your biometric personal data or special categories of personal data.

That said, our Website provides some features that you will only be able to use if we process your personal data. In such a case, we will only process the data that you provide to us, except for data collected automatically (as set out in Section 4 of this Policy). We will not receive your personal data from third parties and will not process such data.

3 HOW DO WE PROCESS YOUR PERSONAL DATA?

We process your personal data both with and without the use of automation tools (mixed processing). When processing your personal data, we perform the following actions (operations) with personal data: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction of personal data.

4 INFORMATION ABOUT YOU THAT IS COLLECTED AUTOMATICALLY. USE OF COOKIES

To improve the Website and make it more user-friendly, relocationcompass may use special cookie technology. In this section of the Policy you can find out what cookies are and how relocationcompass uses them.

What are cookies?

Cookies are small data files that the Website stores on your device and are used to record certain activities on the Website by storing data that can be updated and retrieved. These files are stored on your device and contain data that does not cause damage to your hardware. They are used to record your preferences, such as language selected and access data, and to personalize the Website. Cookies may also be used to store information about how you use the Website. For example, from which page or advertising “banner” you accessed the Website.

What types of cookies does relocationcompass use and for what purposes?

Session cookies: temporary cookies that are stored among your browser’s cookies until you leave the page; these cookies are not stored on your hard disk. The information obtained through these files helps us to analyze the direction of network traffic. Ultimately, they allow relocationcompass to improve the content of the Website and make it easier to use.

Persistent cookies: these cookies are stored on your computer’s hard drive and the Website recognizes them each time you access it. Persistent cookies have a specific expiration date. Once this expiration date has passed, they cease to function. Persistent cookies allow the Website to remember information and settings for future visits by users, thus making browsing more convenient and faster, for example by not requiring you to re-enter your registration details.

Technical cookies: technical cookies are necessary for the proper functioning of the Website and for the correct use of the various personal features and services offered on the Website. For example, such cookies may be used for technical support for the operation of a session, control of response times, operation or confirmation of personal preferences, use of security features, transmission of data via social networks, etc.

Personalization cookies: these cookies allow you to select or personalize certain features of the Website, for example, by defining your language, regional configuration or browser type.

Analytical cookies: relocationcompass uses cookies to obtain information about your browser settings and to analyze your behavior on the Website in order to improve the Website’s performance.

Your ability to manage cookies

You can also withdraw your consent to the processing of cookies and delete the cookies stored on your computer at any time by changing your browser settings. Below you will find links to further information on how to change the settings of your respective browser.

Finally, if you wish to control the setting of cookies, you can install special programs or add-ons in your browser, known as anti-tracking tools, which allow you to choose which cookies you allow to be stored on your device.

5 HOW LONG WE PROCESS YOUR PERSONAL DATA

We process your personal data for no longer than is necessary to achieve the purposes of processing as set out in the Policy.
Once we have achieved the purposes of processing your personal data, we will destroy your personal data (and also ensure that third parties involved in the processing destroy it) within 30 days.

We will also stop processing your personal data (as well as ensure their destruction by third parties involved in the processing) if you withdraw your consent to the processing (in cases where consent is the only legal basis for the processing of your personal data).

Please note that we may, in certain cases, continue to process your data after you have withdrawn your consent, where this is required to fulfill our obligations arising under applicable law or where the processing is necessary for the exercise of the rights and legitimate interests of relocationcompass and/or third parties.
If you wish to withdraw your consent to the processing of personal data, please inform relocationcompass by e-mail.

6 ARE THIRD PARTIES INVOLVED IN THE PROCESSING OF YOUR PERSONAL DATA?

Transmission of personal data as part of business processes

Doing business in today’s environment requires the involvement of many specialists and consultants on technical and other issues, as well as the use of complex information systems and IT infrastructures, including in connection with the processing of your personal data and ensuring their confidentiality and security.

When engaging these third parties for the purposes of processing personal data on its own behalf, relocationcompass, being the operator of your personal data, ensures that these third parties maintain the confidentiality of your data and take the necessary organizational, legal and technical measures for their protection.
The third parties engaged by us will process your personal data solely for the purpose of providing us with the relevant services and for the purpose of carrying out operations with your personal data as defined by us. Under no circumstances shall such persons process your personal data for purposes contrary to the purposes set out in this Policy.

Compliance with Laws, Judicial and Administrative Procedures and Disclosure Obligations

Relocationcompass may transfer your personal data in the following circumstances (where required by or not inconsistent with applicable law):

(A) To comply with applicable law, court decisions, requests from competent public authorities.

(B) In connection with an ongoing investigation.

(C) To investigate or assist in preventing any violation of applicable law as well as this Policy.

If you would like more information regarding third parties who are involved in the processing of your personal data and/or to whom your data is transferred, please send the relevant request to us and we will forward the required information to you.

7 WHAT MEASURES DO WE TAKE TO PROTECT YOUR PERSONAL DATA?

One of the key principles of processing your personal data is to ensure its confidentiality and security. To this end, we have taken and will continue to take technical, legal and organizational security measures in relation to your personal data, in particular:

(A) Appoint a person responsible for organizing the processing of personal data, as well as a person responsible for ensuring the security of personal data in the information system.

(B) Adopt local regulatory acts regarding the processing of personal data.

(C) To conclude contracts with persons processing personal data on behalf of relocationcompass in accordance with legal requirements.

(D) Assess the harm that may be caused to the users of the Website in case of violation of data protection laws, correlate the said harm with the measures taken to ensure the protection of personal data.

(E) Familiarize employees directly involved in the processing of personal data with the provisions of personal data legislation, local regulations on personal data processing and (or) provide training to said employees.

(F) Keep up-to-date records of all persons authorized to access the systems in which personal data are stored, indicating the data processing procedures they are authorized to carry out.

(G) Provide unrestricted access to this Policy.

(H) Protect the premises where the information system where your personal data is processed from uncontrolled intrusion (including by installing locks on the doors of the premises, access control systems, use of video surveillance systems where it is permitted by law).

(I) Protect your information by means of specific data protection measures (including by using a software firewall, modern data exchange methods, implementing secure remote access via external information and communication networks).

(J) Implement appropriate mechanisms, including usernames and secret passwords, to ensure that personal data is accessible only to those authorized to access such data, to the extent that they need such access to perform their duties.

(K) Verify and take measures to ensure that each person authorized to access the systems and/or folders in which personal data is stored is aware of his or her duties and processing procedures relating to such data, as well as of his or her responsibilities.

(L) Enforce the reporting and problem resolution procedures and measures taken to ensure the level of security set out in this Policy.

(M) Install anti-virus programs to protect personal data.

(N) Establish delimited access to personal data processed in the information system(s).

(O) Keep up-to-date incident logs that include the name of the responsible person(s), the time of the incident, the consequences (if any) and the actions taken in the event of a breach of personal data security.

(P) Put in place appropriate procedures for backing up and restoring personal data.
(Q) Ensure that personal data is backed up on a regular basis.

8 YOUR RIGHTS IN RELATION TO THE PROCESSING OF PERSONAL DATA

You have the following rights in relation to the processing of personal data:

(A) To withdraw consent to the processing of your personal data.

(B) To request the clarification, deletion or rectification, as well as the blocking and destruction of incomplete, incorrect, outdated, inaccurate, illegally obtained or not necessary for the processing of personal data.

(C) To access their personal data and, in particular, to obtain the following information:

(i) The categories of personal data processed;

(ii) The purposes for which the personal data are processed;

(iii) details of the persons who have access to the personal data or to whom such access may be granted;

(iv) the list of your personal data being processed and the source of obtaining them;

(v) the timeframe for processing your personal data, including the timeframe for storing it; (vi) other information;

(vi) other information in accordance with applicable law.

9 MODIFICATION OF PRIVACY POLICY

Relocationcompass reserves the right to change and update this Privacy Policy. If we decide to change or update our Privacy Policy, we will post those changes here so that you are always aware of how we process your personal data. If there are any changes to our Privacy Policy, you will be notified by email. If any changes to this Privacy Policy would require, under applicable law, that we obtain your consent to further process your data in accordance with the amended terms of the Policy by sending you a notice, we will ask you for such consent and provide you with an opportunity to opt out of accepting such changes and further processing of personal data.