Policy on Personal Data Processing

1. General Provisions
This personal data processing policy is drafted in accordance with the requirements of the Republic of Moldova Parlament law No. 133 of 07-08-2011 on Personal Data Protection, published on 14-10-2011 in the Official Monitor No. 170-175, article No. 492 and defines the procedure for processing personal data and measures to ensure the security of personal data implemented by the NGO Association for the Development of Innovations and Sustainable Development "Impulse" (hereinafter referred to as the Operator) C/F 1014620000187 .

1.1. The Operator considers the protection of human and civil rights and freedoms, particularly the right to privacy, personal, and family confidentiality, to be its primary objective and essential condition in its activities related to the processing of personal data.

1.2. This policy of the Operator regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website www.innotechforum.vip

2. Key Terms Used in the Policy

2.1. Automated processing of personal data – the processing of personal data using computer technology.

2.2. Blocking of personal data – the temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).

2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, that ensure their accessibility on the internet at the web address www.innotechforum.vip

2.4. Personal data information system – a collection of personal data contained in databases, and information technologies and technical means that ensure their processing.

2.5. Anonymization of personal data – actions that result in it being impossible to determine, without the use of additional information, the association of personal data with a specific User or other subject of personal data.

2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

2.7. Operator – a state body, municipal body, legal entity, or individual that independently or jointly with others organizes and (or) carries out the processing of personal data, as well as determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data – any information directly or indirectly related to a specific or identifiable User of the website www.innotechforum.vip

2.9. Personal data authorized by the data subject for dissemination – personal data to which an unlimited number of individuals have access, granted by the data subject through consent for the processing of personal data authorized by the data subject for dissemination in accordance with the procedure established by the Personal Data Protection Law (hereinafter referred to as personal data authorized for dissemination).

2.10. User – any visitor to the website www.innotechforum.vip

2.11. Provision of personal data – actions aimed at disclosing personal data to a specific
individual or a specific group of individuals.

2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an undefined group of individuals (transfer of personal data) or making personal data available to an unlimited number of people, including the publication of personal data in the media, posting on information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state to a foreign authority, foreign individual, or foreign legal entity.

2.14. Destruction of personal data – any actions resulting in the irreversible destruction of personal data, making it impossible to restore the content of personal data in the personal data information system and (or) the destruction of physical media containing personal data.

3. Main Rights and Obligations of the Operator

3.1. The Operator has the right to:
● Receive accurate information and/or documents containing personal data from the data subject;
● In the event of the data subject withdrawing consent for the processing of personal data, continue processing personal data without the data subject's consent if there are grounds specified in the Personal Data Law;
● Independently determine the scope and list of measures necessary and sufficient to ensure the fulfillment of obligations set forth by the Personal Data Protection Law and the regulations adopted in accordance with it, unless otherwise provided by the Personal Data Protection Law or other federal laws.

3.2. The Operator is obligated to:
● Provide the data subject, upon request, with information regarding the processing of their personal data;
● Organize the processing of personal data in accordance with the current legislation of theRepublic of Moldova;
● Respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Protection Law ;
● Provide the authorized body for the protection of data subjects' rights with the necessary information within 30 days of receiving such a request;
● Publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
● Implement legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, dissemination, and other unlawful actions with regard to personal data;
● Cease the transfer (dissemination, provision, access) of personal data, stop processing, and destroy personal data in the manner and under the circumstances specified by the Personal Data Protection Law;
● Fulfill other obligations stipulated by the Personal Data Protection Law.

4. Main Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:
● Receive information regarding the processing of their personal data, except in cases provided by country laws. The information is provided to the data subject by the Operator in an accessible form and should not contain personal data related to other subjects, unless there are legal grounds for disclosing such data. The list of information and the procedure for obtaining it is established by the Personal Data Protection Law;
● Request that the Operator clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the declared purpose of processing, and take legal measures to protect their rights;
● Set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services in the market;
● Withdraw consent for the processing of personal data;
● Appeal to the authorized body for the protection of personal data subjects’ rights or to a
court regarding unlawful actions or inactions by the Operator in processing their personal
data;
● Exercise other rights provided by the legislation of the Republic of Moldova.

4.2. Data subjects are required to:
- Provide the Operator with accurate information about themselves;
- Notify the Operator about clarifications (updates, changes) of their personal data.

4.3. Individuals who have provided the Operator with false information about themselves, or information about another data subject without the latter’s consent, are liable in accordance with the legislation of the Republic of Moldova.

5. The Operator may process the following personal data of the User:

5.1. For registration and attendance:
- Surname, first name, middle name.
- Email address.
- Phone numbers.

5.2. For speaker and moderator information at our website, social network profiles and printed materials may include such personal data:
- Surname, first name, middle name;
- Email address;
- Phone numbers;
- Position;
- Representing institution or workplace;
- Biography, publications;
- Information on education, experience, fields of expertise;
- Photography and/or video material.

5.3. Additionally, the website collects and processes anonymized visitor data (including "cookie" files) using internet statistics services (Yandex.Metrica, Google Analytics, and others).

5.4. The above-mentioned data in the context of this Policy is collectively referred to as Personal Data.

5.5. The Operator does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, or intimate life.

5.6. Processing of personal data permitted for distribution, from the special categories of personal data mentioned in Personal Data Protection Law, is allowed if the prohibitions and conditions provided by the Law on Personal Data are complied with.

5.7. The User’s consent to the processing of personal data permitted for distribution is obtained separately from other consents to the processing of their personal data. In this case, the conditions stipulated by the Personal Data Protection Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of data subject rights.

5.7.1 The User grants the Operator consent to process personal data permitted for dissemination directly.

5.7.2 The Operator must, within no more than three business days from receiving the User's consent, publish information about the conditions of processing, as well as the existence of any prohibitions and conditions for processing the personal data permitted for dissemination to an unrestricted group of people.

5.7.3 The transfer (dissemination, provision, access) of personal data, permitted by the data subject for dissemination, must be terminated at any time upon request of the data subject. This request must include the last name, first name, patronymic (if applicable), contact information (phone number, email address, or mailing address) of the data subject, as well as a list of personal data whose processing should be terminated. The personal data specified in this request may only be processed by the Operator to whom the request was directed.

5.7.4 Consent to process personal data permitted for dissemination ceases to be valid from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.

6. Principles of personal data processing

6.1 Personal data processing is carried out on a lawful and fair basis.

6.2 Personal data processing is limited to achieving specific, pre-determined, and lawful purposes. Processing of personal data incompatible with the purposes of data collection is not allowed.

6.3 The merging of databases containing personal data processed for incompatible purposes is not allowed.

6.4 Only personal data that corresponds to the purposes of their processing is subject to processing.

6.5 The content and volume of the processed personal data must correspond to the stated purposes of the processing. Excessive processing of personal data beyond the stated purposes is not allowed.

6.6 When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data concerning the purposes of the processing must be ensured. The Operator takes the necessary measures and/or ensures the adoption of such measures to delete or clarify incomplete or inaccurate data.

6.7 Personal data is stored in a form that allows the identification of the data subject, no longer than is required for the purposes of personal data processing, unless a different retention period is established by federal law or a contract in which the data subject is a party, beneficiary, or guarantor. The processed personal data is destroyed or anonymized upon achieving the
purposes of the processing or in the event that the need to achieve those purposes is lost, unless otherwise provided by federal law.

7. Purposes of personal data processing

7.1 The purposes of processing the User's personal data are:
– informing the User by sending emails;
– the conclusion, execution, and termination of civil law contracts;
– providing the User with access to services, information, and/or materials available on the website www.innotechforum.vip

7.2 The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User can always opt out of receiving informational messages by sending an email to the Operator at support@innotechforum.vip with the subject line "Opt-out of notifications about new products, services, and special offers."

7.3 Anonymous User data collected through internet statistics services is used to gather information about User actions on the website, improve the website’s quality, and enhance its content.

8. Legal grounds for personal data processing

8.1 The legal grounds for the Operator's processing of personal data are:
– Republic of Moldova PARLIAMENT LAW No. 133 of 07-08-2011 on personal data protection, published on 14-10-2011 in the Official Monitor No. 170-175, article No. 492;
– other national laws and other regulatory legal acts in the field of personal data protection;
– the Users' consent for the processing of their personal data, including for the processing of personal data permitted for dissemination.

8.2 The Operator processes the User’s personal data only when it is filled in and/or submitted by the User through special forms located on the website www.innotechforum.vip or sent to the Operator via email. By filling out the respective forms and/or sending their personal data to the Operator, the User agrees to this Policy.

8.3 The Operator processes anonymous data about the User if this is permitted in the User's browser settings (e.g., enabling cookie storage and the use of JavaScript technology).

8.4 The data subject independently decides to provide their personal data and consents freely, voluntarily, and in their own interest.

9. Conditions for personal data processing

9.1 The processing of personal data is carried out with the consent of the data subject to the processing of their personal data.

9.2 The processing of personal data is necessary to achieve the purposes provided by the international treaties of the Republic of Moldova or by law, in order to fulfill the functions, powers, and obligations assigned to the Operator by the legislation of the Republic of Moldova.

9.3 The processing of personal data is necessary for the administration of justice, the execution of a judicial act, or an act of another body or official, enforceable in accordance with the legislation of the Republic of Moldova on enforcement proceedings.

9.4 The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the data subject, or a contract under which the data subject will be a beneficiary or guarantor.

9.5 The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that the rights and freedoms of the data subject are not violated.

9.6 The processing of personal data made publicly accessible by the data subject or at the data subject’s request (hereinafter – public personal data) is carried out.

9.7 The processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

10. Procedure for the collection, storage, transfer, and other types of personal data processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

10.1 The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorized access to personal data.

10.2 The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the data subject has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil law contract.

10.3 If inaccuracies are found in the personal data, the User can update them independently by sending a notification to the Operator at the email address support@innotechforum.vip with the subject line "Personal Data Update."

10.4 The duration of personal data processing is determined by the achievement of the purposes for which the personal data was collected unless another period is specified by the contract or applicable law. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at support@innotechforum.vip with the subject line "Withdrawal of Consent to Personal Data Processing."

10.5 All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The data subject and/or User is responsible for familiarizing themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including service providers mentioned in this paragraph.

10.6 Restrictions set by the data subject on the transfer (except for access provision), as well as on the processing or conditions of processing (except for access provision) of personal data permitted for dissemination, do not apply in cases of personal data processing in state, public, and other public interests as defined by Republic of Moldova law.

10.7 If inaccuracies are found in the personal data, the User can update them independently by sending a notification to the Operator at the email address support@innotechforum.vip with the subject line "Personal Data Update."

10.8 The duration of personal data processing is determined by the achievement of the purposes for which the personal data was collected unless another period is specified by the contract or applicable law. The User can withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at support@innotechforum.vip with the subject line "Withdrawal of Consent to Personal Data Processing."

10.9 All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The data subject and/or User is responsible for familiarizing themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including service providers mentioned in this paragraph.

10.10 Restrictions set by the data subject on the transfer (except for access provision), as well as on the processing or conditions of processing (except for access provision) of personal data permitted for dissemination, do not apply in cases of personal data processing in state, public, and other public interests as defined by Republic of Moldova law.

10.11 The Operator ensures the confidentiality of personal data during their processing.

10.12 The Operator stores personal data in a form that allows identifying the data subject no longer than required by the purposes of personal data processing, unless the retention period for personal data is established by federal law, a contract to which the data subject is a party, beneficiary, or guarantor.

10.13 The condition for terminating the processing of personal data may be the achievement of the purposes of personal data processing, the expiration of the consent of the data subject, the withdrawal of consent by the data subject, or the discovery of unlawful processing of personal data.

11. List of actions performed by the Operator with the received personal data

11.1 The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

11.2 The Operator performs automated processing of personal data with the receipt and/or transfer of the obtained information via information and telecommunications networks or without such networks.

12. Cross-border transfer of personal data

12.1 Before the start of the cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the personal data is to be transferred provides reliable protection of the rights of data subjects.

12.2. Cross-border transfer of personal data to foreign countries that do not meet the above requirements can only take place with the written consent of the data subject for the transfer of their personal data and/or for the fulfillment of a contract to which the data subject is a party.

13. Confidentiality of Personal Data
The Operator and other parties with access to personal data are prohibited from disclosing or distributing personal data to third parties without the consent of the data subject, unless otherwise required by federal law.

14. Final Provisions

14.1. Users may request clarifications regarding the processing of their personal data by contacting the Operator via email at support@innotechforum.vip

14.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The policy remains in effect indefinitely until replaced by a new version.

14.3. The current version of the policy is freely available online at support@innotechforum.vip
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