Privacy policy

Processing of Personal Data shall be carried out in accordance with the provisions of the Federal Law dated 27.07.2006 No. 152-FZ "On Personal Data", other applicable regulatory legal acts of the Russian Federation, as well as the Operator's internal documents regulating the procedure for processing and protection of Personal Data.

The legal bases for processing Personal Data are:

1. Consent of the personal data subject. Processing is carried out on the basis of the personal data subject's free, voluntary and fully informed consent to the processing of his/her data for purposes determined in advance by the Operator. The subject of personal data has the right to withdraw his/her consent at any time by sending a relevant notice. At the same time, withdrawal of consent does not affect the lawfulness of the processing carried out prior to its withdrawal and entails termination of data processing, unless otherwise provided for by law.
2. Conclusion and execution of a contract. Processing is necessary for the execution of a contract to which the personal data subject is a party, or for the performance of actions preceding its conclusion at the initiative of the subject.
3. Fulfillment of the requirements of the legislation of the Russian Federation. Processing is necessary to fulfill the Operator's statutory obligations, including, but not limited to, obligations in the field of tax and accounting, financial control, consumer legislation, as well as obligations to provide information to authorized state bodies in cases provided for by law.

In general, the operator does not verify the reliability of the personal data provided, does not control the capacity of personal data subjects. The risk of providing unreliable personal data, including the provision of data of third parties as their own, is borne by the subject of personal data.

The Operator assumes that the user provides true and sufficient information on matters offered in the forms of the Site or by providing consent and keeps this information up to date.

In order to provide access to the Site, we ask users for information about themselves, such data can be categorized as follows:

Response to Request. To respond to your request left through the Site, the Operator will process your data to answer your request.

The operator will process the following data:

• Your name;
• E-mail;
• Phone Number.

The basis for processing the listed personal data will be your request.
The personal data processed for the above purpose do not belong to special categories or biometric data and are processed in an automated manner.
The Operator will destroy personal data as soon as it decides your request. If a contract is concluded with the Operator, the Operator will continue to process personal data for its fulfillment.

Execution of the contract. In order to execute the contract, the Operator will need your data for identification purposes.

The operator will process the following data:

• Your first and last name;
• Details of the identity document;
• Bank details;
• E-mail;
• Phone number.

The basis for the processing of the listed personal data will be the performance of the contract.

The personal data processed for the above purpose do not belong to special categories or biometric data and are processed in an automated manner.

Personal data is processed prior to the execution of the contract.

Receive information about the Operator's activities. Upon receipt of your consent, the Operator will notify you of new products and offers. The Operator will process the following data:

• Your name;
• E-mail;
• Phone Number.

The basis for processing your personal data in this process is your consent. You have the right to withdraw your consent to the processing of personal data, for this purpose, apply to the Operator with a free-form application.

The personal data processed for the above purpose do not belong to special categories or biometric data and are processed in an automated manner.

Personal data will be processed until you opt out of receiving the information.

The Operator is constantly improving the Website, expanding its functionality and introducing new features. In this regard, the list of personal data to be collected, specified above, may be subject to change. In order to use new features, the Operator has the right to request additional information from you. In this case, you will be notified of the relevant changes in advance and will be asked to provide consent to the collection and processing of additional Personal Data.

Please note that the provision of personal data is voluntary. Nevertheless, refusal to provide them may result in the inability to use certain functions of the Site.

The Operator does not perform automated decision-making, nor does it use Personal Data for automated analysis or assessment of personal characteristics (including profiling).

Personal data is stored exclusively for the period necessary to realize the purposes for which it was collected and processed.

Please note that in certain cases Personal Data may be retained longer than the specified period if required by applicable laws and regulations.

The Operator does not perform cross-border transfer of Personal Data, i.e. does not transfer Personal Data of Personal Data subjects to the territory of foreign countries.

All actions on collection, systematization, storage, clarification (update, change), use, depersonalization and destruction of Personal Data shall be carried out exclusively using databases located in the territory of the Russian Federation.

In case the need for trans-border transfer of Personal Data arises in the future, the Operator will ensure compliance with all requirements established by the legislation of the Russian Federation, including obtaining the consent of the Personal Data subject (in cases provided for by law), as well as transferring data only to those countries that ensure adequate protection of the rights of Personal Data subjects, or if there are other legal grounds.

The Operator shall take the necessary legal, organizational and technical measures to protect Personal Data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions in relation to such data.

In order to ensure the security of Personal Data, the Operator implements the following measures:

• identification of threats to the security of Personal Data when processed in personal data information systems (PDIS);
• application of organizational and technical measures to ensure the security of Personal Data during their processing in the ISPDN, necessary to meet the requirements to the protection of Personal Data established by regulatory legal acts;
• Establishing rules for access to Personal Data, as well as ensuring that all actions with Personal Data are recorded and accounted for;
• use of anti-virus protection, firewalls, intrusion detection systems and other information protection tools;
• regular monitoring and evaluation of the effectiveness of the measures taken to ensure the security of Personal Data;
• Maintaining internal documentation on the issues of processing and protection of Personal Data.

We periodically evaluate and update our security measures to reflect changes in law, technology, and threats. This allows us to respond quickly to potential risks and improve the protection of your Personal Data.

In accordance with the legislation of the Russian Federation, the User as a subject of personal data has the following rights:

• Right to information regarding the processing of Personal Data. The User has the right to receive information regarding the processing of his/her Personal Data.
• Right of access to his/her Personal Data. The User has the right to request the Operator to provide a copy of the Personal Data processed in relation to him/her.
• The right to clarify, block or destroy Personal Data. The User has the right to demand from the Operator:

• clarification of his/her Personal Data in case it is incomplete, inaccurate or outdated;
• blocking or destruction of data if they are redundant, processed unlawfully, or are no longer required for the stated purposes of processing.

• Right to withdraw consent to the processing of Personal Data. The User may revoke his/her consent to the processing of Personal Data at any time by sending a corresponding notice to the Operator. In this case, data processing will be terminated, unless otherwise provided for by applicable law.
• Right to appeal against actions or inaction of the Operator. In case of disagreement with the Operator's actions related to the processing of Personal Data, the User has the right to appeal against them to the authorized body for the protection of the rights of personal data subjects (Roskomnadzor) or in court.

Please note that none of the above rights are absolute, which means that they generally have to be weighed against Our own legal obligations and legitimate interests. If a decision is made to refuse your request, We will inform you of this together with the reasons for our decision.

To exercise any of the rights listed above, please contact us at the contact details provided in this Policy.

If you believe that your rights to the protection of Personal Data have been violated, you have the right to lodge a complaint with the competent authority that supervises the processing of Personal Data.

The Operator shall not be liable for possible misuse of personal data and causing any damage to the user, which occurred due to:

technical failures in software and technical facilities and networks beyond the control of the Operator;

in connection with the intentional or unintentional use of the Site not for its intended purpose by third parties;

failure to ensure confidentiality of access passwords or deliberate transfer of access passwords, other information from the Site by the user when receiving Operator's services or using the Site to other persons who do not have access to this information;

unlawful actions of third parties to access the Site data, including personal data.

The Operator hereby reserves the right to amend this Policy at its discretion and at any time by publishing its amended version on the Website. The new version of the Policy will include the changed date of the last update on its first page.

The User undertakes, at his/her own risk, to continuously check for changes to the Policy and perform the following actions: (i) memorize/mark the last update date specified in the Policy (e.g. keep a copy of the Policy, etc.), (ii) regularly visit the relevant page of the Site and study the document in case the update date changes.

The event that you do not agree with any changes to the Policy, you must immediately stop using the Site.

The Site is not intended for persons under the age of 18. We do not knowingly collect personal data about anyone under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with personal data without their consent, he or she should contact us at the details set out in the Policy. If we become aware that a person under the age of 18 has provided us with personal data, we will delete such information and cease processing and accessing the Site.

The Operator uses cookies and similar technologies to improve the functionality of the Site, analyze user experience, monitor the use of Site functionality, and provide personalized content and advertising.

When you visit the Site for the first time, we ask for your consent to place cookies on your device.

You can manage cookies through your browser settings. You have the right to refuse the use of cookies, however, this may limit the functionality of the Site.

Identity theft and the practice now known as "phishing" are of great concern to the Operator. Safeguarding information to protect you from identity theft is our top priority. We do not and will not ask for your credit card information, login details or national identification numbers in unsecured or unsolicited emails or over the phone.