Main Media Center,
April 15-16, 2019
I. General provisions
Relations involving processing of personal data and information about users of the Website are governed by this Regulation, other official documents of the Operator and the current legislation of the Russian Federation.
We carry out personal data processing on a legal and fair basis, acting reasonably and in good faith following the principles of:
This Policy extends to the processing of personal data collected by any means, both active and passive, both online and offline, from individuals located anywhere in the world.
II. Collection of personal data
The purpose of personal data processing is to fulfill the Operator’s obligations to Users in relation to the use of the Website and its services.
Processing of users’ personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
Personal data is understood as any information directly or indirectly related to an identified or an identifiable person (the subject of personal data) which can be used to identify a particular person or communicate with them.
Below are some examples of types of personal data that the Company may collect, and how we can use this information.
TYPES OF PERSONAL DATA WE COLLECT
We may collect various data/information, including:
Personal data may also include additional data provided by Users at the request of the Operator in order to fulfill the Operator’s obligations to Users arising from the service contract. The Operator has the right, in particular, to request from the User a copy of an identity document or other document containing the User’s first name, last name, photo, as well as other additional data that, at the Operator’s discretion, may be necessary and sufficient to identify such User and eliminate abuse and violation of the rights of third parties.
When you involve other persons in our events or activities or invite them to communicate with us, the Company may collect the personal data you provide about these individuals, such as: first name, last name, date of birth, postal address, e-mail address and phone number.
When processing personal data, we ensure the accuracy of personal data, its sufficiency, and, if necessary, its relevance to the purposes of personal data processing.
III. Storage and use of personal data
Users’ personal data is stored exclusively in electronic media and processed using automated systems, except for cases when manual processing of personal data is necessary in connection with the implementation of legal requirements.
HOW WE USE YOUR PERSONAL INFORMATION
The personal data we collect allows us to notify you about new products, special offers and various events. It also helps us improve our services, content and communications. If you do not wish to be included in our mailing list, you can unsubscribe at any time by addressing the specified contacts for feedback, as well as making changes to your profile settings on the Website.
From time to time, we may use your personal information to send important notices containing information about changes in our terms, conditions and policies, as well as confirming your orders and purchases. Since such information is essential to your relations with the Company, you cannot refuse to receive such messages.
We may also use personal information for internal purposes, such as: conducting audits, analyzing data and carrying out various studies in order to improve the Company’s products and services, as well as our interaction with consumers.
If you participate in a prize drawing, competition or similar incentive event, we reserve the right to use the personal data provided by you to manage such programs.
COLLECTION AND USE OF NON-PERSONAL INFORMATION
We also collect data that is not personal–data which is not directly associated with any particular person. We may collect, use, transfer and disclose information that is not personal, for any purpose. Below are examples of non-personal information collected by us, and how we can use it:
We may collect such personal data as information on user’s occupation, language, zip code, unique device identifier, location and time zone in which a particular product is used, in order to better understand consumer behavior and improve our products, services and communications.
If we combine non-personal information with personal information, such aggregate information will be treated as personal information as long is such information is combined.
IV. Transfer of personal data
Users’ personal data is not transferred to any third parties, except for the cases directly provisioned by this Regulation.
Users’ personal data processing is carried out without any time limit, in any legal way, including in personal data information systems with or without the use of automation tools.
If the User specifies it or gives their consent, it is possible to transfer the User’s personal data to third parties-contractors of the Operator on the condition that such contractors undertake to ensure confidentiality of the information received, in particular, when using applications.
Applications used by Users on the Website are placed and maintained by third parties (developers) who operate independently of the Operator and do not act on behalf of or by order of the Operator. Users are required to familiarize themselves with the rules for the provision of services and policies on the protection of personal data of such third parties (developers) before using the relevant applications.
Users’ personal data may be transferred at the request of authorized government bodies of the Russian Federation only on the grounds of, and in the manner established by the legislation of the Russian Federation.
In case unreliable personal data or illegal actions are revealed, the Operator shall block the personal data of the respective User from the moment the User, or their legal representative, or authorized body for protection of the rights of subjects of personal data, contacts the Operator or requests such blocking for the duration of the verification period.
DISCLOSURE OF INFORMATION TO THIRD PARTIES
In some cases, the Company may provide certain personal information and data to strategic partners working with the Company to provide products and services, or partners helping the Company sell products and services to consumers. Third parties are provided with minimum amount of personal data required only to provide the required service or perform the necessary transaction.
Personal information will only be provided by the Company in order to supply consumers with products and services, as well as to improve these products and services and related communications. Such information will not be provided to third parties for their marketing purposes.
In order to use your personal data for any other purpose, we will request your consent to the processing of your personal data.
The Company provides personal data/information to companies rendering such services as information processing, credit granting, execution of customer orders, delivery, other consumer services, determining your interest in our products and services, conducting surveys aimed at studying our consumers or their satisfaction with the quality of our service. Such companies are obliged to protect your information regardless of country of their location.
The Company may be required to disclose your personal information in accordance with the law, judicial procedure, in court proceedings and/or on the basis of public inquiries or requests from state authorities on the territory or outside the territory of your host country. We may also disclose personal data/information about you if we determine that such disclosure is necessary or appropriate for national security, law enforcement or other socially important cases.
We may also disclose personal data/information about you if we determine that disclosure is necessary in order to enforce our terms and conditions or to protect our activities and our users. Additionally, in case of reorganization, merger or sale, we may transfer any or all personal information collected by us to the appropriate third party.
V. Destruction of personal data
Personal data of the User is destroyed when:
- the User independently deletes data from their personal page using the “delete account” function available to the User through profile settings;
- the Operator deletes information placed by the User, as well as the User’s personal page in cases established by the purchase/sale agreement (offer);
- the subject of personal data withdraws consent to the processing of personal data.
IDENTIFICATION FILES (COOKIES) AND OTHER TECHNOLOGIES
Our goal in such cases is to provide more convenient and personal interaction with the Company. For example, knowing your name, we can use it in our communications. Knowing that someone using your computer or device purchased a certain product or used a certain service, we can provide advertising and e-mail messages better corresponding to your interests. Ultimately, all this knowledge helps us provide you with the highest quality service.
You can disable cookies in the settings of your web browser or mobile device. It should be noted that some functions of the website may become unavailable after disabling cookies.
As with most websites, we collect some information automatically and store it in the statistics files. Such information includes the address of the Internet protocol (IP address), the type and language of the browser, information about the Internet service provider, the login and logout pages, information about the operating system, the date and time stamp, and information about visits. We use this information to understand and analyze trends, administer the website, study the user behavior on the website and collect demographic information about our primary user population in general. The company may use this information for marketing purposes.
In some of our e-mail messages, we use interactive links to information posted on the Company’s website. When users click these links their requests go through a separate registration before they reach the destination page on our website. We monitor such “passing” data in order to determine the interest in certain topics and measure the effectiveness of our communications with consumers. If you prefer your messages not to be tracked this way, you should not click text or graphic links in our e-mail messages.
Pixel tags allow us to send e-mail messages in a format readable to consumers, and inform us whether such messages were read. We may use this information to limit the number of messages sent to consumers or stop sending them.
VI. Protection of personal data
The company takes precautions–including legal, organizational, administrative, technical and physical–to ensure the protection of your personal data in accordance with Art. 19 of Federal Law No. 152-FZ “On Personal Data” dated July 27, 2006, in order to protect the User’s personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.
When you use certain products, services or applications of the Company or post entries on forums, in chat rooms or social networks, the personal data you provide is visible to other users and can be read, collected or used by them. You are responsible for the personal data that you prefer to provide in such cases. For example, if you specify your name and e-mail address in a forum entry, such information is public. Please take precautions when using these functions.
INTEGRITY AND PRESERVATION OF PERSONAL INFORMATION
We do not collect minors’ personal data. If we become aware that we have received a minor’s personal data, we will take steps to remove such information as soon as possible.
We strongly recommend that parents and other persons supervising minors (legal representatives–parents, adoptive parents or guardians) should control the use of websites by minors.
THIRD-PARTY WEBSITES AND SERVICES
Websites, products, applications and services of the Company may contain links to websites, products and services of third parties. Our products and services may also use or offer third-party products or services. Personal data and information collected by third parties, which may include such information as location data or contact information, is governed by the privacy practices of such third parties. We encourage you to study the privacy practices of such third parties.
The Operator is not responsible for the actions of third parties who have access to information about the User as a result of using the Internet or the Services of the Website, and the consequences of using the data or information that, by virtue of the Website’s nature, is accessible to any Internet user.
PROTECTION OF YOUR CONFIDENTIALITY AT THE LEVEL OF THE COMPANY
In order to ensure that your personal data is safe, we make sure the Company’s employees are familiar with our standards of confidentiality and security, and strictly monitor compliance with the confidentiality measures within the Company.
QUESTIONS REGARDING CONFIDENTIALITY
VII. User requests
Users have the right to send their requests to the Operator, including requests in regard to the use of their personal data or withdrawal of consent to the processing of personal data in writing to the address specified in the General provisions of this Provision, or in the form of an electronic document signed by a qualified electronic signature in accordance with the legislation of the Russian Federation, and sent by means of a feedback form.
The request sent by the User must comply with the requirements established by the Rules for filing applications addressed to the Support Service, namely it must contain:
The Operator shall review and forward the response to the received User’s request within 30 days from the receipt of the request.
This Policy does not apply to the actions and Internet resources of third parties.