Personal Data Protection Policy of Netregistr ("Privacy Policy")

Netregistr (hereinafter referred to as the "Company") is committed to conducting business in full compliance with all applicable laws, particularly those related to the protection of Personal Data. We respect the privacy rights of all individuals and ensure that Personal Data is safeguarded at every stage of our business processes.

For the purposes of this Privacy Policy, "Company" refers to Netregistr IT Consultancy.

This Privacy Policy outlines the types of Personal Data collected, the purposes for which the data is gathered, used, or disclosed, the retention period, and the categories of individuals or entities to whom the Company may disclose the collected Personal Data. It also describes data subject rights and the security measures implemented to protect Personal Data in compliance with legal provisions, as well as other relevant details regarding the Company's Personal Data management.

This Privacy Policy is also considered part of the terms and conditions for using the Company's services. The Company may amend, update, modify, or change this policy as necessary. Any changes will be communicated to you, and your consent will be requested in accordance with applicable Personal Data protection laws.

1. Definition

  • "Personal Data" refers to any information related to an individual that enables the identification of such a person, whether directly or indirectly, but does not include information of a deceased person, as specified by the applicable Personal Data Protection Laws.
  • "Sensitive Personal Data" refers to specific categories of Personal Data as defined by applicable Personal Data Protection Laws, including but not limited to racial or ethnic origin, political opinions, religious or philosophical beliefs, sexual orientation, criminal records, health data, disability status, trade union membership, genetic data, biometric data, or any other data that may affect the data subject in the same manner as prescribed by the competent authority.
  • "Data Subject" refers to an individual who owns the Personal Data collected, used, or disclosed by the Company.
  • "Data Controller" means a person or entity having the authority to make decisions regarding the collection, use or disclosure of Personal Data.
  • "Data Processor" refers to a person or entity that collects, uses, or discloses Personal Data on behalf of and under the instructions of the Data Controller. The Data Processor does not have independent authority to decide on the purposes or means of processing Personal Data.

2. Scope of this Privacy Policy

  • This Privacy Policy applies to Data Subjects whose Personal Data is processed by the Company, including its officers, employees, business units, or any other entities operated by the Company. It also applies to third-party Data Processors that handle Personal Data on behalf of the Company in relation to the Company’s products and services, such as websites, applications, documents, or other communication channels (collectively, the "Services").
  • Individuals who have a relationship with the Company under the provisions of the above paragraph include:
    1. Individual customers, candidates
    2. Officers or operators
    3. Individual vendors and service providers
    4. Directors, attorneys, representatives, agents, shareholders, employees or other individuals that are related to the business of the Company
    5. Users of the Company’s products or Services
    6. Visitors or users of the Company’s website including systems, applications, devices or other communication channels which controlled by the Company
    7. Other individuals whose the Company collects the Personal Data from, such as job applicants, relatives of the employees and beneficiaries in the insurance policy, etc.
  • Items A - G are collectively called “You.”
  • In addition to this Privacy Policy, the Company may issue a Privacy Notice ("Notice") for certain products or services. In the event of a conflict between this Privacy Policy and a Notice, the provisions of the Notice shall prevail.

3. Personal Data that the Company collects, uses, or discloses

  • The Company may collect, use, or disclose, including cases where you have provided your consent to the Company, as follows. This depends on the Services you may use or the context of your relationship with the Company and other considerations that apply to the Personal Data collection.
  • Types of Personal DataDescriptions and Examples
    Personal DataYour identifiers or information from official documents, such as name, signature, ID number, passport number, etc.
    Personal Characteristic InformationDate of birth, gender, marital status, language skills, etc.
    Contact InformationPhone numbers, email addresses, physical address, social media usernames.
    Employment and Educational InformationWork history, occupation, tax ID, salary, education details.
    Insurance Policy InformationPolicyholder, beneficiary, policy number, claims history.
    Social Relationship InformationPolitical affiliations, contractor/customer status, stakeholder details.
    Service Usage InformationAccount name, password, OTP, browsing history, cookies, etc.
    Sensitive Personal DataEthnicity, religion, disability, political opinions, biometric, health info.
  • Note: If you do not provide consent for the processing of certain Personal Data, the Company may not be able to offer specific services. This may impact contractual obligations, service performance, or legal compliance.

4. Source of the Receipt of Your Personal Data

  • The Company may collect your Personal Data directly from you or from other sources such as affiliates, third-party providers, or publicly available sources. This includes communications, forms, websites, applications, and interactions with our staff or agents.

5. Purpose for Personal Data Collection

  • The Company collects and processes your Personal Data for the following purposes:
    • Providing and improving services
    • Compliance with contractual and legal obligations
    • Marketing and promotional communications
    • Managing relationships with customers and vendors
    • Responding to inquiries or complaints
    • Recruitment and employment processing
    • Internal audits, investigations, and dispute resolution

6. Disclosure of your Personal Data

  • The Company may disclose your Personal Data to affiliates, partners, service providers, legal authorities, regulatory bodies, and other third parties necessary to fulfill the purposes described. All recipients are bound to confidentiality and data protection obligations.

7. Sending or Transferring of Personal Data Overseas

  • When transferring your Personal Data overseas, the Company ensures that appropriate safeguards and legal mechanisms are in place to protect the data according to applicable laws and standards.

8. Storage of Personal Data and Duration of Storage of Personal Data

  • Your Personal Data will be stored for as long as necessary to fulfill the purposes outlined or to comply with legal obligations. Once no longer needed, data will be securely deleted or anonymized.

9. Services provided by third parties or sub-provider

  • Some Company services may rely on third-party providers. These third parties may collect and process your Personal Data under their own privacy policies and contractual agreements with the Company.

10. Connecting to external websites or services

  • Company services may link to external websites or services not operated by the Company. The Company is not responsible for the privacy practices of such third-party services. You are encouraged to review their privacy policies separately.

11. Security of your Personal Data

  • The Company implements appropriate technical and organizational measures to safeguard your Personal Data against unauthorized access, disclosure, alteration, or destruction.

12. The Rights of the Owner of the Personal Data

  • You have rights under applicable data protection laws, including the right to:
    • Access and obtain a copy of your Personal Data
    • Rectify inaccurate or incomplete data
    • Object to processing or request data deletion
    • Restrict processing
    • Withdraw consent at any time
    • Lodge a complaint with a supervisory authority

13. Cookies

  • The Company’s website uses cookies and similar technologies to enhance user experience, analyze traffic, and provide personalized services. You may manage cookie settings through your browser or device.

14. Amendments on Personal Data Protection Policy

  • This Privacy Policy may be amended or updated from time to time. The latest version will be published on our website, and material changes will be communicated to you as required by applicable laws.

Last reviewed: January 7, 2025