Privacy policy
This Privacy Policy (hereinafter referred to as the «Policy») establishes the procedure for collecting, processing, storing, transferring, and disclosing the personal data of users (hereinafter referred to as «Users») that the company «Mirsatori» (hereinafter referred to as the «Company») receives when Users use the Site https://mirsatori.com/ (hereinafter referred to as the «Site»).
1. Introduction
The Company collects, processes and stores personal data in accordance with the requirements of applicable data protection legislation, including UAE Federal Law No. 45 of 2021 (UAE PDPL), Regulation (EC) 2016/679 (GDPR), the California Consumer Protection Act (CCPA) and other international standards.
By using the Site, the User agrees to the provisions of this Policy, including the rules for the collection, storage, use, and disclosure of personal data established by applicable law. This also confirms the User's consent to the exercise of all rights and obligations provided by law.
Principles
Personal data is processed entirely on a legal basis for the purposes of providing information to individuals, concluding and executing contracts, in accordance with the following principles:
- good faith and reasonableness in the processing of personal data;
- transparency and legality;
- limitation to the achievement of specific purposes provided for by this Policy and concluded agreements;
- use of the minimum amount of personal data necessary to achieve the purposes provided for by this Policy and concluded agreements;
- security and storage limitations.
2. Definitions of Terms
For the purposes of this Policy, the terms defined below shall have the following meanings:
- «Site» — a web resource located on the Internet at the address: https://mirsatori.com/ , which is an information and communication platform used to present, promote and provide migration, legal and other related services, as well as for information exchange between the Company and the User.
- «User» — a natural person, legal entity, or other organization with full legal capacity in accordance with the laws of their country of residence, who uses the Site.
- «Company» — means «Mirsatori», a limited liability company, incorporated under the laws of the United Arab Emirates, at Business Center 1, M Floor, The Meydan Hotel, Nad Al Sheba, Dubai, U.A.E.
- «Site Administration» — employees authorized to manage the Site, acting on behalf of the Company.
- «Personal data» — any information related to a specific individual (data subject) that allows direct or indirect identification of that individual. Such information includes, among other things, information that allows identification of the individual, as well as data related to the use of the Site, if they directly or indirectly allow identification of the User.
3. Collection and processing of personal data
When using the Site, personal data is collected and subsequently processed, including its collection, storage, use, transfer, and other actions with it, to the extent and for the purposes required by applicable personal data protection laws, including international standards.
When using the Site, the following technical data may be automatically collected:
- IP address;
- browser type and version;
- information about the operating system;
- language settings;
- date and time of access to the Site;
- referral source (URL address);
- pages viewed, duration of visit;
- actions and other interactions performed on the Site (for example, clicking buttons, scrolling the page and other actions).
Data is collected using tracking technologies, including cookies. The use of cookies is governed by a separate Cookie Policy. When accessing the Site from mobile devices, information about the device and its parameters may also be collected, including information about failures and other system events, as well as the source of the transition and other actions related to the use of the Site.
During the use of the Site, in particular when filling out feedback forms, ordering a service, sending a request or performing other actions, the following categories of personal data may be processed:
| Data category | Purposes of processing and other actions |
|---|---|
| Name, surname |
|
| Email and phone number |
|
| Country of location |
|
The Company may receive information from trusted external sources, including affiliates, partner organizations, publicly available resources, and other lawful sources. The received data may be used and processed, including combining with existing data, to fulfill obligations and other actions within the framework of this Policy.
Personal data is processed for the following purposes:
- provision of services requested through the Site;
- preparation and sending of commercial proposals;
- fulfillment of obligations under contracts;
- conducting business correspondence and performing other actions related to servicing;
- analytical processing of data to improve the quality of services;
- ensuring compliance with the terms of the Company's Rules and Policies;
- prevention and investigation of illegal actions;
- sending information and marketing materials with the User's consent with the ability to refuse at any time;
- other actions necessary to implement the rights and legitimate interests of the Company and the User.
4. Social networks
The Company uses social networks for various purposes, including promoting its services, advertising its products, and improving the quality of its services. In doing so, personal data may be exchanged between the Company and the relevant social network providers in accordance with the terms and conditions set out in the privacy policies of these platforms. The User has the right to refuse to use the functionality related to social networks.
Social media plugins and widgets
The Site may incorporate social media plugins and widgets (e.g., «Share» buttons). When interacting with such elements, certain information may be automatically transmitted to the relevant social media provider.
Other social networking services
The Company may use additional social network services (e.g. messengers) to organize interaction with Users on issues related to the services provided. Official accounts may also be maintained on social networks.
When interacting with such services, social network providers may request and receive information related to the User (e.g. email address, etc.) within the framework of the user's consent.
5. Disclosure of information
Personal data will not be transferred to third parties not associated with the Site and the Company's activities, except in cases where there are legal grounds for doing so and the conditions set forth in this Policy are met. Personal data may be transferred to companies, organizations, or individuals not affiliated with the Company if there are reasonable grounds to believe that such transfer is necessary and justified for:
- compliance with applicable laws, regulations, court decisions, or lawful requests from government authorities;
- ensure compliance with the law, including investigating alleged violations;
- identify, prevent, or address fraud, security, or technical issues;
- protect the rights, property, safety, or public interests of the Company, its Users, or the public within the limits established by law;
- fulfilling the terms of the agreement between the User and the Company;
- assisting in the provision of services by third parties necessary for the Company to fulfill its obligations.
In the event of a merger, acquisition, reorganization, or transfer of assets, the Company undertakes to ensure the confidentiality of personal data and to notify Users prior to such transfer or change in the terms of this Policy. Unless otherwise provided by this Policy or the terms of the agreements, information that identifies the User (including name, email address, and other personal data) is not disclosed to other Users of the Site.
6. Storage, security and cross-border transfer of personal data
The Company undertakes to take all reasonable measures to protect personal data from unauthorized access, modification, disclosure, misuse or deletion. The Site is equipped with the necessary security tools to protect users' personal data. To ensure the safety and protection of personal data, corporate security systems and procedures are used, including technical and physical restrictions on the use of and access to personal data stored on the Company's servers.
Access to personal data is provided exclusively to authorized employees of the Company and persons involved in the technical maintenance of the Site, who undertake to maintain confidentiality and take measures to prevent unauthorized access by third parties. The Site servers may be located outside the User's country of residence. By providing personal data, the User agrees to their transfer, storage and processing outside their country in accordance with applicable law. In the event of unauthorized access to personal data, the Company is not responsible for the actions of third parties, including hackers and other violators of the law who may attempt to use personal data for personal purposes.
In accordance with the legislation of the European Union, the data storage period may be from 6 to 10 years from the moment of the User’s last action on the Site or from the moment of termination of relations with the Company, depending on the nature of the documentation (contracts, notifications, business correspondence, etc.). After the expiration of the specified period, personal data shall be deleted or de-identified, if their further storage is not required to comply with the requirements of the law, resolve disputes or protect the legal rights of the Company, fulfill contractual obligations, or fulfill audit and tax obligations.
In cases where the immediate deletion of data is impossible or undesirable for legal reasons, their processing is subject to restriction — access to such data is blocked until the expiration of the storage period or the statute of limitations.
7. Use of automated decision making
We hereby inform you about the use of automated solutions, including profiling, used to optimize interaction with the User. Such algorithms analyze, for example, the history of views and interactions with advertising materials on the Site, in order to personalize content and improve the quality of services provided.
The User has the right to object at any time to the processing of his personal data using automated methods. To exercise this right, it is necessary to send a written objection to the e-mail address: office@mirsatori.com.
8. Changes to this Privacy Policy
The Company reserves the right to make changes and additions to this Privacy Policy without prior individual notification to Users. The updated version of the Policy is posted on the Company's official Site and comes into force from the moment of its publication, unless otherwise specified in the document itself. Continued use of the Site and/or services after changes have been made shall be deemed as the User's consent to the updated terms and conditions. In certain cases, the Company may request explicit confirmation of the User's consent to the new version of the Policy through a special notification.
9. User rights
The Company carries out the collection, processing, storage and protection of personal data in accordance with the requirements of the UAE Federal Decree-Law No. 45 of 2021 on the protection of personal data (UAE PDPL), as well as taking into account international standards, including Regulation (EU) 2016/679 (GDPR), California Consumer Privacy Act (CCPA) and Zambia Data Protection Act (ZOPL). The Company strives to provide Users with full control over the use of their personal data. The following options are available for this purpose:
- Request an overview of the personal data held by the Company and receive information on how it is used;
- Report any changes to the personal data or request correction of inaccuracies in the data held by the Company;
- Request deletion, blocking or restriction of the processing of personal data, as well as refuse specific methods of using it;
- Notify the Company of your desire to transfer your personal data to third parties;
- Revoke previously provided consent to the processing of personal data at any time in accordance with applicable law;
- Prohibit the use of personal data if it is processed on the basis of legitimate interests or public objectives, within the framework of applicable law.
The User is obliged to ensure that the personal data provided is complete, accurate and up-to-date.
To gain access to information, correct it, delete it or take other actions, you must send a request to the email address: office@mirsatori.com.
10. Protection of personal data
In accordance with the applicable laws of the country of citizenship or permanent residence of the data subject, the Company provides additional information as required by the relevant legal acts.
In compliance with the requirements of Articles 37-39 of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (GDPR), the Company has appointed a data protection officer.
His/her functions include:
- informing employees about the requirements of personal data protection legislation;
- conducting internal audits for compliance with applicable regulations;
- assessing and preventing risks associated with the processing of personal data;
- advising data subjects on the processing procedure, their rights, and the measures applied to ensure information security.
If you have any comments, questions, or requests related to the provisions of this Privacy Policy, as well as questions regarding the processing, correction, deletion, or use of personal data, please send an email to: office@mirsatori.com.
11. Final provisions
This Policy is available in Russian and English. Both versions are posted on the Site and are available for selection through the language settings in the interface. In the event of discrepancies between the Russian and English versions, the English version shall prevail, unless otherwise expressly provided by applicable law.