PRIVACY POLICY Sessa Capital
This Confidentiality Policy is applied to all information that SessaCapital’s website may receive about the User while using the said company’s website.
1. TERMS AND DEFINITIONS
1.1 The following terms are used in this Confidentiality Policy as follows:
1.1.1. “Website Administration” means authorized employees of the Website Administration acting on behalf of Sessa Capital, who arrange and/or carry out the processing of personal data, the definition of the purposes of this processing, the selection of data to be processed, actions (manipulations) with the above data.
1.1.2. "Personal data" mean any information relating to a person, directly or indirectly determining
1.1.3. “Personal data processing” mean any actions (manipulations) or their combination with personal data carried out with or without automated devices, including, collecting, recording, organizing, accumulating, storing, updating (modifying), selecting, using, transferring (distribution, provision, access), depersonalization, blocking, deletion, destruction.
1.1.4. “Confidentiality of personal data” means a mandatory requirement to prevent the dissemination of personal data of their subject without his consent, relating to the operator or another person having access to the said data.
1.1.5. “User” means a person who has access to the Company’s Website via the Internet.
1.1.6. Cookie means small pieces of data sent by a web server and stored on a user's computer and sent by a web client or a user's web browser to a web server every time an HTTP request is made while trying to open the page of the corresponding website.
1.1.7. “IP address” means a unique network address of a node in a computer network built using the IP protocol.
2. GENERAL PROVISIONS
2.1. The User's application of the company's website means his/her consent and acceptance of this Policy and all conditions for processing personal data of the user.
2.2. In case of disagreement with the provisions of this Policy, the User shall be obliged to stop using the Company's Website.
2.3. This Policy shall be applied only to the Sessa Capital website. The Company's Website shall not control and shall not be liable for third-party websites that the User can access by clicking on the links available on the company's website.
2.4. The Website Administration shall not verify the authenticity of personal data provided by the User on the Company's Website.
3. SUBJECT MATTER OF THIS POLICY
3.1. This Policy establishes the responsibilities of the Company's Website Administration for non-disclosure and establishment of a security regime in relation to the confidentiality of personal data that the user provides to the Administration of the website during registration.
3.2. Personal data permitted to be processed in accordance with this Policy shall be provided by the User by completing the registration form on the Sessa Capital website in the registration section and include the following information about the User:
3.2.1. Surname and first name;
3.2.2. Contact number;
3.2.3. E-mail address;
3.2.4. Accounts in social networks;
3.3. The Company's Website protects the following data, which is transmitted automatically during scanning and when visiting pages with an established statistical script:
IP address;
information from cookie files;
information about the browser;
access time;
page address;
User activity on the page;
page redirect to the current (the address of the previous page).
3.3.1. Turning off cookies may make it impossible to access parts of the Company’s Website where authorization is required.
3.3.2. The Company's website collects statistics on the IP address of all visitors. This information helps to find and solve technical problems and control the legality of financial transactions.
3.4. Any other personal information not mentioned above (history of operations, browsers used, operating system, etc.) is subject to safekeeping and non-proliferation, due to the thinning of the cases described in paragraph 5.2 of this Policy.
4. PURPOSE OF COLLECTING PERSONAL INFORMATION OF USERS
4.1. The Company's Website Administration may use the User’s personal data for the following purposes:
4.1.1. To identify the User registered on the Company's Website for the purpose of securing remote financial transactions with Sessa Capital.
4.1.2. Providing the User with access to the personalized resources of the Company’s Website.
4.1.3. Associating the User’s feedback, including sending out notifications, newsletters, inquiries regarding the use of the Company's Website, the provision of services, the processing of inquiries and the statements of the User.
4.1.4. Determine the location of the User for security purposes and to prevent fraud.
4.1.5. Confirmation of the authenticity and completeness of personal data provided by the User.
4.1.6. Create an account for financial transactions, if the User agrees to create an account.
4.1.7. Sending notifications to the Company Website about news and actions.
4.1.8. Processing the financial information of the User.
4.1.9. Providing effective customer and technical support to the User in case of problems with the use of the Company's Website.
4.1.10. Providing the User via e-mail special offers, information on financial transactions, newsletters, and other information on behalf of the Company Site.
4.1.11. Implementation of promotional activities with the consent of the User.
5. METHODS AND REGULATIONS ON THE USER’S PERSONAL DATA PROCESSING
5.1. The User’s personal data are processed out of time, in any legal way, including the use of personal data systems with or without automated work tools.
5.2. The User agrees with the Administration’s right to transfer personal data to third parties, in particular, electronic postal services for the subsequent delivery of correspondence, solely for the purpose of fulfilling the Company's obligations to the User.
5.3. In case of loss or disclosure of personal data, the Website Administration shall notify the User thereof.
5.4. The Website Administration shall take all required organizational and technical measures to protect the User’s personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution or other, including illegal actions by third parties.
5.5. The Website Administration together with the User shall take all required measures to prevent loss of funds or other negative consequences of the loss or disclosure of the User’s personal data.
6. PARTIES’S OBLIGATIONS
6.1. The User shall be obliged:
6.1.1. To provide information about personal data required to use the Company’s Website.
6.1.2. To update, supplement the information provided about personal data in case of any amendments thereto.
6.2. The Website Administration shall be obliged:
6.2.1. To use the information obtained solely for the purposes specified in paragraph 4 of this Policy.
6.2.2. To take measures to keep confidential information confidential, not to disclose it without the prior written consent of the User, save for the exceptions mentioned in paragraph 5.2 of this Policy.
6.2.3. To take precautionary measures in relation to the confidentiality of the personal data of the User in accordance with the usual practices applicable to the protection of such information in similar existing organizations.
6.2.4. Block personal data relating to a specific User since the moment of creating a request from the User or his legal representative, or an authorized person of this User, in order to protect the rights of the subject of personal data for the period of verification in case of finding personal data, whose authenticity is in doubt, or unlawful acts.
7. PARTIES’ LIABILITY
7.1. In case of failure to fulfill the obligations, the Website Administration shall be liable for losses incurred by the User in connection with the unlawful use of his personal data.
7.2. In case of loss or disclosure of confidential information, the Website Administration shall not be liable if the information mentioned is:
7.2.1. It became publicly available prior to its loss or disclosure.
7.2.2. It was received from third parties prior to its receipt by the Administration Website.
7.2.3. It was disclosed with the consent of the User.
8. DISPUTE SETTLEMENT PROCEDURE
8.1. Prior to filing an application with the court with a claim regarding a dispute arising out of the relationship between the User and the Website Administration, the parties shall be obliged to file pre-trial claims.
8.2. The claimee shall be obliged to notify the applicant in writing of the results of its consideration on the merits thereof within 30 calendar days upon the receipt thereof.
8.3. If it is impossible to reach an agreement, the dispute may be submitted to the court for further settlement.
9. MISCELLANEOUS
9.1. The Website Administration shall be entitled to amend this Policy without the User’s prior consent.
9.2. The new version of this Policy shall become effective upon its publication on the Company’s Website unless otherwise indicated in the aforementioned new version.
9.3. Any suggestions or questions regarding this Policy should be addressed to the technical support service of the Company’s Website.
9.4. This Confidentiality Policy is published on the page