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Privacy Policy


POLICY OF PERSONAL DATA PROCESSING IN SMMPAK
1. GENERAL PROVISIONS

1.1. This document defines the policy of SMMPAK regarding the processing of personal data (hereinafter referred to as PD) and contains information on the implemented measures to protect PD.
1.2. LLC "SMMPAK" independently processes PD, determines the purposes of PD processing, the composition of PD to be processed, actions (operations) performed with PD, and also in some cases entrust the processing of PD to other persons.
1.3. When processing PD, SMMPAK  is guided by the following principles:
processing is carried out on a legal and fair basis;
processing is limited to the achievement of specific, predetermined and legitimate purposes;
processing incompatible with the purposes of collecting personal data is not allowed;
combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not allowed;
only PD that meet the purposes of their processing are subject to processing;
the content and volume of processed personal data corresponds to the stated purposes of processing;
when processing PD, their accuracy, sufficiency and, if necessary, relevance in relation to the purposes of PD processing are ensured;
1.4. On the basis of this policy, SMMPAK develops internal regulatory documents that establish procedures for processing and protecting the processed PD.

2. TERMS AND DEFINITIONS

2.1. Personal data - any information relating directly or indirectly to a specific or identifiable individual (subject of personal data).
2.2. Operator (of personal data) - a state body, a municipal body, a legal entity or an individual, independently or jointly with third parties organizing and (or) processing personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions ( operations) performed with personal data.

2.3. Processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data , including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use , transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.4. Automated processing of personal data - processing of personal data using computer technology;

2.5. Dissemination of personal data - actions aimed at disclosing personal data to an indefinite circle of persons;
2.6. Providing personal data- actions aimed at disclosing personal data to a certain person or a certain circle of persons;
2.7. Blocking of personal data - temporary termination of PD processing (except in cases where processing is necessary to clarify PD);

2.8. Destruction of personal data - actions as a result of which it becomes impossible to restore the content of PD in the information system of personal data and (or) as a result of which material carriers of PD are destroyed;
2.9. Personal data information system - a set of personal data contained in databases and information technologies and technical means that ensure their processing;
2.10. Cross-border transfer of personal data- transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual or a foreign legal entity.

3. PURPOSES OF PROCESSING

3.1. SMMPAK carries out PD processing for the following purposes:
registering users on the SMMPAK Holidays website and accepting payments for the subsequent provision of training services;
obtaining additional information in the interests of the subject of personal data;
obtaining information for posting a curriculum vitae of SMMPAK Holidays teachers on the school's website in the public domain;
organizing and conducting advertising and marketing events for consumers of SMMPAK products;

conducting loyalty programs for consumers of SMMPAK products;
registration of participants in the program for professional photographers;
fulfillment of obligations stipulated by the current legislation of the Pakistan Federation.
3.2. To achieve the goals of PD processing, SMMPAK carries out the following operations with PD: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction PDn.

4. RECEIPT AND PROCESSING

4.1. PDN processed by SMMPAK receives:
directly from the subject of personal data;
on behalf of a person who is not a PD subject;
from publicly available PD sources.
4.2. In LLC "SMMPAK" PD processing is carried out exclusively on legal grounds. In all cases stipulated by the legislation of the Pakistan Federation, SMMPAK organizes the receipt of the consent of the PD subject for the processing of his PD in writing or in another form that allows to confirm the fact of its receipt.
4.3. Receiving PD from a person who is not a PD subject is carried out if there are the following grounds:
to achieve the goals stipulated by the legislation of the Pakistan Federation, or to implement and fulfill the functions, powers and duties assigned by the legislation of the Pakistan Federation to SMMPAK;
for the execution of an agreement, to which the PD subject is either a party or a beneficiary or guarantor, as well as for concluding an agreement on the initiative of the PD subject or an agreement under which the PD subject will be the beneficiary or guarantor;
to exercise the rights and legitimate interests of SMMPAK or third parties, provided that this does not violate the rights and freedoms of the PD subject;
PD processing is carried out, access to an unlimited number of persons to which is provided by the PD subject or at his request (PD made by the publicly available PD subject);
processing of personal data subject to publication or mandatory disclosure in accordance with federal law.
4.4. In LLC "SMMPAK" PD processing is carried out both with the use of automation tools and without the use of such tools.
4.5. To achieve the stated goals, SMMPAK processes personal data of customers (consumers of SMMPAK products) and their authorized representatives; professional photographers; students at SMMPAK Holidays.
4.6. SMMPAK does not carry out actions aimed at disclosing PD to an indefinite circle of persons (i.e., it does not distribute PD), except for the cases of posting a curriculum vitae about SMMPAK School teachers on the school's website in the public domain with the appropriate permission of the PD subject ...
4.7. SMMPAK does not disclose and does not provide third parties with PD without the consent of the PD subject obtained in the form required by the legislation of the Pakistan Federation.
4.8. To fulfill the functions, powers and duties imposed by the legislation of the Pakistan Federation, as well as to achieve its statutory goals and contractual obligations, SMMPAK provides a part of the processed PD:
to the law enforcement agencies of the Pakistan Federation (upon request) and other authorized organizations;
to the parent organization - SMMPAK Corporation, SMMPAK Pakistan;
to courier, transport and logistics organizations that deliver SMMPAK products;
to call centers that provide customer call services as part of a customer satisfaction survey;
to banks that provide services for lending to customers;
to authorized service centers that provide services for warranty and non-warranty repair of SMMPAK equipment;
to agencies that are organizers of marketing events, promotions, contests.
4.9. SMMPAK does not process special categories of PD related to race, nationality, political views, religious or philosophical beliefs, health status, intimate life, as well as PD on the convictions of PD subjects.
4.10. SMMPAK does not process biometric PD.
4.11. SMMPAK carries out cross-border transfer of personal data to the territory of Great Britain, Germany, the Netherlands, Japan and the United States of America, while obligatorily ensures the existence of the necessary legal grounds for this, provided for by Article 12 of the Federal Law of 27.07.2006 No. 152-FZ "On personal data ".
4.12. The databases of information used by SMMPAK containing personal data of citizens of the Pakistan Federation are located on the territory of the Pakistan Federation.
4.13. SMMPAK does not make decisions that give rise to legal consequences in relation to the PD subject or otherwise affect his rights and legitimate interests, on the basis of solely automated processing of PD.
4.14. In LLC "SMMPAK" PD processing can be carried out in order to promote goods and services on the market by making direct contacts with a potential consumer using communication means only subject to obtaining the prior consent of the PD subject.

5. STORAGE OF INFORMATION

5.1. PD processing at SMMPAK is carried out no longer than the purpose of PD processing requires.
5.2. SMMPAK organizes the storage of personal data during the time established by the requirements of the Federal Law of October 22, 2004 No. 125-FZ "On Archival Affairs in the Pakistan Federation" and "The List of Typical Administrative Archive Documents Generated in the Process of the Activities of State Bodies, Local Self-Government Bodies and organizations, indicating the storage periods "(Appendix to the order of the Ministry of Culture of the Pakistan Federation dated 25.08.2010 No. 558), as well as in some cases during the time established by the agreement, the party to which, the beneficiary or the guarantor of which is the PD subject.
5.3. When the goals of PD processing are achieved, in case of loss of the need to achieve these goals, at the end of the storage period for PD, the processed PD is destroyed.

6. PROTECTION OF INFORMATION

6.1. SMMPAK takes the necessary legal, organizational and technical measures to protect the processed PD from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of PD, from other illegal actions in relation to PD.
6.2. In SMMPAK, by orders, persons are appointed responsible for organizing the processing of PD and for ensuring the security of PD.
6.3. SMMPAK has defined a list of persons whose access to personal data processed in information systems is necessary to fulfill their official (labor) duties.
6.4. In LLC "SMMPAK" measures are taken to record and ensure the safety of personal data carriers.
6.5. LLC "SMMPAK" assesses the harm that may be caused to PD subjects, as well as regularly analyzes the conditions and factors that create threats to the security of PD during their processing.
6.6. In the cases stipulated by the legislation of the Pakistan Federation, within the framework of the personal data protection system of SMMPAK, information protection means are used that have passed the conformity assessment procedure in accordance with the established procedure.
6.7. Commissioning of new personal data information systems is carried out only after the procedures for assessing the effectiveness of measures taken to ensure the security of personal data have been completed.
6.8. Within the framework of the PDN protection system, SMMPAK implemented:
physical security of the premises in which the technical means of personal data information systems are located;
the use of the necessary software and hardware-software means of protection, in particular, means of protection against unauthorized access, means of differentiating access and registration of user actions, anti-virus protection means, security analysis, intrusion detection, backup, firewalls when interacting with the Internet;
organizational measures to ensure the security of personal data, adopted and approved by the management of SMMPAK, in particular, procedures were implemented for establishing rules for access to PD, registration and accounting of all actions performed with PD, procedures for restoring PD modified or destroyed due to unauthorized access to them, accounting of machine carriers of PD, procedures for training and raising awareness of employees on issues of ensuring PD security, procedures for monitoring the measures taken to ensure PD security and the level of PD security

7. USE OF COOKIE TECHNOLOGY

7.1. Visiting smmpak's website involves obtaining certain information about the user through cookies.
7.2. What is a cookie?
Cookies are pieces of data that your web browser stores on your computer's hard drive or in the memory of your mobile device. When you visit the website again, the server automatically recognizes the corresponding cookie, which contains information about the last use of the website.
We use cookies to optimize the user experience on our website and to better understand how it is used. For example, we can use cookies to determine if you have visited our website before or if you are a new visitor. These cookies can also "remember" your shopping preferences and help ensure that online ads are shown that are relevant to your interests. SMMPAK may also monitor the popularity of various parts of the website and improve navigation, but this information will not be combined with your personal information.
7.3. Types of cookies.
There are two broad categories of cookies.
Essential cookies, stored directly by the SMMPAK website on your computer or mobile device. They are only used by SMMPAK to recognize your computer or mobile device when you revisit our website.
Third-party cookies, which are transmitted by service providers on our website and may be used by these service providers to recognize your computer or mobile device when you visit other websites. Third party cookies are most commonly used for analytical or advertising purposes.
Cookies can be stored on your computer or mobile device for different periods of time. Some cookies are "session" cookies, meaning that they only exist while your browser is open. They are automatically deleted when you close your browser. Other cookies are "persistent", meaning that they continue to exist even after you close your browser. They can be used by the SMMPAK website to recognize your computer or mobile device when you reopen your browser and browse the Internet.

7.4. What kind of cookies do we use?
Our website uses the following types of cookies:
- Type of cookies: Cookies required for basic functionality
Purpose: These cookies are essential to provide you with the services available through our website and to use some of its features. In particular, they allow our website to remember choices you have made - for example, posts you have starred. They cannot track your activity on other websites.

- Cookie type: Analytical cookies
Purpose: These cookies are used to collect information about the use of our website by visitors. The information collected does not identify the visitor and is generalized. It includes the number of visitors to our website, the addresses of the sites from which they came to our website, and the pages they viewed on our website. We use this information to improve your experience on our website, collect broad demographic data and track the level of activity on our website.

- Cookie type: Behavioral cookies
Purpose: These cookies collect information about the behavior of visitors on our website, so that we can analyze traffic. For this purpose, we use the Google Analytics service. Google Analytics uses its own cookies. These cookies do not collect information that personally identifies the visitor. All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the performance of the site. More information about Google Analytics cookies is available here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies... If you do not want Google Analytics to collect data about your use of our website, download and install the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en
- Type of files cookies: Social media cookies
Purpose: These cookies are used when you share information on social media by clicking the Share or Like button on our websites, link your account or comment on our content via social media such as Facebook, Twitter or Google+. The social network will record your action. This information can be used to highlight target groups or highly targeted advertising.

7.5. How to control and delete cookies
Most browsers accept cookies automatically. In your browser settings, you can turn off automatic acceptance and / or prevent the storage of cookies from this website on your computer or mobile device. To do this, follow the instructions for your browser (usually they are found in the Preferences, Help, Tools, or Edit menu). If you choose not to accept cookies, you can still use most of the features on our website, but you may be denied access to parts of the site that depend on cookies.

8. DISCLOSURE OF INFORMATION

8.1. On behalf of SMMPAK, a notification about PD processing was sent to the authorized body for the protection of the rights of PD subjects.
8.2. To ensure unrestricted access to the policy of SMMPAK regarding the processing of personal data and information on the measures taken to protect personal data, the text of this Policy is published on the official website of SMMPAK www.smmpak.store .
8.3. Ensuring the implementation of the rights of PD subjects is carried out through the execution of requests from individuals to SMMPAK at the address:
Postal address: 105120, Pakistan Federation, Punjab, 2nd NBK GUJ per., 1;
Email address: admin@smmpaak.store .