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Privacy Policy

dated June 19, 2024

1. General provisions

  • Service: the Flomni Omnichannel Platform software for processing messages, registered in the Russian Software Register under No. 17699 dated May 19, 2023 (the Service)
  • Access to the Service is available at: https://flomni.com/en/ (the Website)
  • This Policy defines the procedure for processing the personal data of Website and Service users
  • Operator: OMNITECH LLC
    TIN: 7840061562
    Phone: +7 (812) 627-14-53
    Address: 4/23 Lit. A, Premises 13N, Sergey Tyulenin Lane, Municipal District No. 78, St. Petersburg, 191186, Russia
  • Users (the User):
    Website user: an individual aged 18 or older who has provided their personal data to the Operator.
    Service user: legal entities, as well as individuals aged 18 or older who have provided the personal data of their clients to the Operator with their consent.
  • Contact for requests:  welcome@flomni.ru

2. Collection of personal data

  • The Operator collects personal data in electronic form where this is necessary for entering into and performing a contract, or with the User's consent.
  • Data may be obtained:

    a) when the Service User enters data in the User's personal account within the Service
    b) when completing the callback request form (for pre-contractual purposes) at  https://flomni.com/en/

3. Actions performed in connection with the processing of personal data

Collection; recording; systematization; accumulation; storage; clarification (updating, modification); extraction; use; transfer (provision, access); blocking; deletion; destruction.

4. Purposes, timeframes, and legal grounds for
the processing of personal data

4.1. The Operator uses personal data collected on the Website solely for the purposes set out below:

Purpose Categories of Data Retention Period
To review User requests (pre-contractual purposes)
  • Full name
  • E-mail
  • Phone number
  • Company name

Until the earliest of the following, depending on which occurs first:

  • conclusion of a contract with the User
  • expiry of 1 year
  • withdrawal of the User's consent
To improve Website performance and maintain analytics
  • Technical device data
  • Data on the User's interaction with the Website and actions taken on the Website

Until the earliest of the following, depending on which occurs first:

  • expiry of 15 days
  • withdrawal of the User's consent
To create a personal account in the Service
  • Full name
  • E-mail
  • Company name
 Until the User deletes their personal account in the Service
To use the Service functionality (sending and collecting messages via messengers)

Personal data of the User's clients (data subjects), obtained with their consent and required by the Operator to perform the Service agreement, including:

  • Full name
  • Phone number
  • Other data independently entered by the User when using the Service

Until the earliest of the following, depending on which occurs first:

  • expiry of 1 year
  • the User's request to stop processing the data

4.2. Legal Grounds for Processing for the Above Purposes:

  • compliance with the Operator's rights and legitimate interests and those of third parties;
  • the data subject's consent to the processing of personal data;
  • performance of a contract to which the data subject is a party or beneficiary.

5. Procedure for processing personal data (excluding cookies)

  • The Operator processes only personal data that does not fall within special categories of personal data or biometric personal data.
  • The User's personal data is processed using automated means.
  • The Operator does not carry out cross-border transfers of personal data. Processing is performed using databases located in the territory of the Russian Federation.
  • The Operator takes the legal, organizational, and technical measures required by law to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, disclosure, dissemination, and other unlawful actions.

6. Cookie processing procedure

  • Cookies are small pieces of text sent to the browser from the Website. They allow the Website to remember information about the User's visit, making interactions with the Website easier and more useful for the User.
  • For the purposes of personal data processing set out in Section 4 of this Policy, the Operator uses cookies.
  • Cookies may also be processed through web analytics services.
  • Users may be shown pop-up notices about the collection and processing of cookies, including a link to this Policy and buttons to accept the processing terms or close the notice.
  • If the User does not agree to the processing of cookies, the User accepts the risk that certain functions and features of the Website may not be fully available.

7. Amendment and deletion of personal data

  • If personal data changes, the User must update it independently by submitting changes through the form on the Website or by notifying the Operator at  welcome@flomni.ru
  • Upon expiry of the processing period or withdrawal of consent, the User's personal data is deleted from the Operator's information systems without the possibility of recovery.

8. Transfer of personal data

8.1. Personal data may be transferred to third parties only in the following cases:

  • if the personal data subject has given consent;
  • to law enforcement authorities in the course of inquiry or investigation;
  • on the basis of an instruction to a personal data processor.

8.2. The Operator may transfer personal data to third parties whose involvement is necessary for the proper functioning of the Service, including:

8.2.1. The full scope of processed personal data is transferred for the use of the processor's server infrastructure to:

  • Yandex LLC (TIN: 7736207543, address: 16 Leo Tolstoy St., Moscow, 119021);
  • Selectel LLC (TIN: 7842393933, address: Lit. A, 21 Tsvetochnaya St., St. Petersburg, 196006)

8.2.2. Data on technical devices, the User's interaction with the Website, and the User's subsequent actions on the Website are transferred for analytics purposes to:

  • Yandex LLC (TIN: 7736207543, address: 16 Leo Tolstoy St., Moscow, 119021)

8.2.3. Personal data of the User's clients (personal data subjects), obtained with their consent and required by the Operator to perform the Service agreement, is transferred for message delivery through the following providers:

  • V Kontakte LLC (TIN: 7842349892, address: 1H, Lit. A, 12–14 Khersonskaya St., St. Petersburg, 191024);
  • Odnoklassniki LLC (TIN: 7705773443, address: Bldg. 79, 39 Leningradsky Ave., Moscow, 125167);
  • KEX eCommerce LLC (TIN: 7710668349, address: Floor 15, Room 1, 7 Lesnaya St., Moscow, 125196);
  • MegaFon International JSC (TIN: 7706683030, address: Office 11.04, 41 Oruzheyny Lane, Moscow, 127006);
  • MTS PJSC (TIN: 7740000076, address: 4 Marksistskaya St., Moscow, 109147);
  • VimpelCom PJSC (TIN: 7713076301, address: Bldg. 14, 10 8 Marta St., Moscow, 127083);
  • T2 Mobile LLC (TIN: 7743895280, address: Office 33, Floor 5, Bldg. 6, p. 1, 22nd km of Kyiv Highway, Moscow, 108811);
  • SKARTEL LLC (TIN: 7701725181, address: Office 48, 41 Oruzheyny Lane, Moscow, 127006);
  • Tinkoff Mobile LLC (TIN: 7743200179, address: Floor/Premises 25/25022, Bldg. 1, 5 Golovinskoye Highway, Moscow, 125212).

8.3. Any person to whom the Operator discloses personal data must comply with the principles and conditions of its processing established by the agreement with the Operator, including confidentiality obligations, as well as the requirements of this Policy and Federal Law No. 152-FZ dated July 27, 2006, On Personal Data.

9. User rights

Protection of personal data
  • The Operator protects personal data from unauthorized or accidental access.
  • Key protection measures include:
    1. a. implementation of technical safeguards for information stored on electronic media;
    2. b. establishment of access control rules for personal data.
    3. c. the Operator blocks personal data at the User's request if:
      • the personal data is inaccurate;
      • the personal data is being processed unlawfully.
Amendment of personal data
  • The User may amend or update personal data by contacting the Operator at  welcome@flomni.ru ;
  • The Operator must update the data within 7 business days after receiving the request.
Transfer of Personal Data
  • The Operator may transfer the User's personal data to third parties not listed in Section 8 of this Policy only where required by law, as well as in the User's interests for the purpose of providing consulting services.
Provision of personal data
  • The User may request any information regarding the processing of their personal data by emailing  welcome@flomni.ru  with the subject line "Request for Personal Data Information"
  • The response period for a User request for access to their personal data is 10 business days.

10. Policy Amendments

  • The Operator may amend this Policy without the User's consent. The updated version of the Policy takes effect once published on the Website, unless otherwise provided in the new version.
  • The current version of the Policy is available on the Website.

Version dated June 19, 2024

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