Personal Data Processing Policy
OOO Ulyana Sergeenko
1. General Provisions
1.2. To Use Company Services and to provide User’s personal information means that the User gives its unreserved consent to follow this Policy and personal data processing conditions stated in it; if the User does not agree to follow this Policy, they shall refuse from Using the website.
1.3. The Company proceeds from the assumption that the User initiating the Use can reasonably define their demands and control technical parameters of their equipment, that they have examined this Policy in full. If the User does not agree to follow the Policy, they shall stop Using the website.
2. User’s Personal Data
2.1. Within this Policy, the “User’s personal data” means:
2.1.1. Any personal data that the User provides about themselves while registering (creating an account) or Using the website, including but not limited to:
Full name (surname, name, patronymic);
ID or passport number:
Land-line (mobile) telephone number;
Payment details (credit/debit card number, bank account number, etc.);
User’s name (login) and password;
Age (date of birth), etc.
2.1.2. Any data that is automatically transferred via the software installed in the User’s device while the User uses the website, including IP address, cookies, User’s browser information (or any other program which grants the access to the website), technical characteristics of the equipment and software used by the User, date and time of access, addresses of the pages visited, and other similar information.
2.1.3. Any other information about the User which can be obtained due to the technical capability.
2.2. The Company shall not validate the personal data provided by the User and has no opportunity to check their capability. Nevertheless, the Company and the User proceed from the assumption that the User provides true and sufficient personal data and keeps the data up-to-date.
3. Purposes of User’s Personal Data Processing
3.1. The Company shall keep and store personal data that is only required for providing/obtaining the Use, except for cases when the law demands to store personal data for a specified period of time.
3.2. The User’s personal data shall be processed for the following purposes:
3.2.1. To identify the party that Uses the website and follows agreements and contracts with the Company;
3.2.2. To provide to the User an opportunity for a customized Use and fulfillment of agreements and contracts;
3.2.3. To communicate with the User, including sending notifications, requests and information about the Use, fulfillment of agreements and contracts, and to process requests and claims of the User, including possible information e-mails;
3.2.4. To send commercial and information e-mails containing information about new collections, future and current discounts, other Company’s events, via telecommunication networks, including via telephone, fax, mobile wireless communication (e-mail, telephone, etc.). The User is entitled to refuse from receiving commercial and other information without explanation by informing the Company about it via any means of communication that is convenient for the user;
3.2.5. To improve the quality and convenience of the Use, to develop new opportunities and options of the Use;
3.2.6. To target advertising materials;
3.2.7. To undertake statistical and other studies based on anonymized data.
4. Conditions of the User’s Personal Data Processing and its Transfer to the Third Parties
4.1. Concerning the User’s personal data, it shall be kept confidential, except for cases when the User voluntarily discloses their data to the shared access of the general public. While using some of the Use options, the User agrees that some of their personal data becomes open to the general public.
4.2. The Company is entitled to transfer the User’s personal data to the third parties in the following cases:
4.2.1. The Uses gives their consent to this;
4.2.2. The transfer is required so that the User could use one of the Use options or fulfill a particular agreement or contract with the User;
4.2.3. When the User uses functions and services of the companies providing financial services;
4.2.4. The transfer is made according to the Russian or any other applicable laws within the procedure stated by the law;
4.2.5. The transfer is made as a part of the sale or any other transfer of business (in full or in part), provided that the purchaser acquires all obligations to follow the conditions of this Policy in relation to the obtained data;
4.2.6. To provide an opportunity to protect rights and legal interests of the Company or any third parties if the User violates the provisions of current laws of the Russian Federation in this sphere, or the documents containing the conditions of the use of particular Use options, and this document.
4.2.7. When the User’s personal data is processed by anonymizing it, it may lead to anonymized statistical data that is transferred to the third party for a study, provision of works or services upon the Company’s request.
4.3. While processing the Users’ personal data, the Company follows the Federal Law of the Russian Federation “On Personal Data”.
5. Personal Data Change and Anonymization. Obligatory Data Storage
5.1. The User is entitled to change (update, add) previously provided personal data or its part at any time.
5.2. The User is also entitled to delete previously provided personal data within the specified personal account.
5.3. The rights stated in cl. 5.1. and 5.2. hereof may be limited according to the law. In particular, such limitations may include the Company’s obligation to store changed or deleted User’s data for a period specified by the law, or to transfer such data according to the legal procedure stated by the government authority.
6. Cookies and Counters Personal Data Processing
6.1. Cookie files contained in the User’s equipment for any reason may be used by the Company to provide customized use options to the User, to target/send information/advertisement that is shown to the User, for statistical and research purposes, and to improve the Use options.
6.2. The User is aware that the equipment and software used for the Use may have a function to prohibit cookie file operations (for any or specified websites) and to delete previously obtained cookie files.
6.3. The Company is entitled to determine that the provision of particular Use options is possible only if the User agrees to obtain and receive cookie files.
6.4. The structure of cookies, their content and technical parameters shall be determined at the Company’s discretion and may be changed without the User’s prior notification.
6.5. The counters placed by the Company for the Use may be used to analyze the User’s cookie files, to collect and process statistical data and for other purposes. Technical parameters of counters shall be determined by the Company and may be changed without the User’s prior notification.
7. Protection of User’s Personal Data
7.1. The Company shall take required and sufficient organizational and technical measures to protect the User’s personal data from unlawful or accidental access, destruction, change, blocking, copying, distribution, and other unlawful actions of any third parties.
7.2. The Company shall use the User’s profile information (login and password) to authorize the access to the Use. The User shall be liable for the safety of such information (login and password). The Company shall consider any actions made using such information as actions made by the User. The User shall not provide their login and password to any third parties.
If the User learns the login and password of another user or any confidential information about another user, they shall inform the Company about it and shall not use the data that became known to them.
7.3. The User’s access to the Use may lead to the Internet websites of any third parties and the download of software programs and/or graphic images (including those invisible for the Internet browser) that are used for commercial purposes and for the statistics collection. Owners of such websites have technical capability to collect User’s data, and they determine the data use conditions on their own.
By software adjustment, the User is entitled to block graphic images requests on the third party servers, however, it may lead to lower readability and more errors in website display.
While transferring from the Company’s User pages to the third party Internet websites, the User shall on their own determine the limits of the data use within the terms and conditions provided by the owners of corresponding Internet websites.
7.4. User’s personal data protection shall be obtained via monitoring the risks of personal data safety during its processing; implementing organizational and technical measures to protect personal data during its processing; evaluating the effectiveness of such measures to protect personal data; detecting unauthorized access to the Personal Data and providing measures to prevent it; determining personal data access regulations; controlling the measures to protect personal data.
9. Feedback. Rights and Obligations of the Parties
9.1. The User is entitled to send any offers or questions related to this Policy to the Company’s Help Desk at the address: 123001, Moscow, Granatniy pereulok, house 4, building 4, office 11, or via phone +7 495 105 70 25 or e-mail email@example.com.
9.2. The Website User shall have the rights according to the current laws of the Russian Federation.
9.3. While visiting and Using Company’s Internet websites, the User shall: follow the provisions of the current laws of the Russian Federation and this document; compensate for the losses suffered by the Company, other Users or any third parties as a result of the violation of the Policy or the laws of the Russian Federation; follow the provisions of documents regulating the Use, and the laws of the Russian Federation; examine the legal information published on the Website or accessible via links.
9.4. While Using the website, the User shall not: publish or distribute any information that may:
contain threats, damage, insult, discredit honor, dignity or business reputation, or invade the privacy of other Website Users or any third parties;
violate the rights of minor children;
be indecent, contain strong language, contain pornographic images and texts or sexually suggestive scenes with the involvement of minors;
contain graphic violence or inhumane treatment of animals;
contain description or means and types of suicide, any instigation to suicide;
propagate and/or support racial, religious, ethnic hatred or feud, propagate fascism or racial superiority ideology;
contain extremist materials;
propagate criminal activity or contain advice, instructions or guides to commit criminal actions;
contain restricted access information, including but not limited to government and commercial secrets, third party privacy data;
contain advertisement or attractively describe narcotic substance use, drug distribution information, preparation methods and how to use them;
violate third party intellectual property rights;
violate rights of personal data subjects;
violate other rights and interests of individual and legal entities or provisions of the Russian Federation laws.
9.5. The User shall not:
provide bulk e-mailing;
use software or provide actions aimed at the violation of normal functioning of technical opportunities and equipment of the Company;
publish or distribute on the Website or in any other way use viruses, Trojans and other malicious software;
publish commercial or political advertisement on the Website;
provide any other actions that may harm the Company, third parties, or Users.