Date: December 6, 2021
1. Subject matter
2. Personal Data processing
The Organizer, or its affiliated entity that provides the Services in other jurisdictions, collects and uses the Personal Data of the User to allow the use of the Website and Services.
3. Policy’s Purpose
The Organizer protects and processes the Personal Data in strict compliance with applicable law.
4. Personal Data collected by Organizer
The Organizer collects the following categories of the Personal Data during the User’s usage of the Website and Services:
(i) Personal Data provided by the User such as a name, telephone number, etc.;
(ii) electronic data such as HTTP-headers, IP address, cookie files, web beacons/pixel tags, User Agent data and information about software and hardware;
(iii) date and time of the User’s access to the Website and/or Services;
(iv) information on the User’s actions on the Website and/or during the use of the Services;
(v) geolocation data;
The Organizer uses cookie files and web beacons (including pixel tags) to collect Personal Data and link those with the User’s device and browser.
The Organizer collects data for the purposes of the applicable law and does not use those to restrict the User’s rights and freedoms.
5. Lawfulness of Personal Data processing
The Organizer processes the Personal Data for the purposes of:
(i) fulfillment of the Organizer’s obligations under the agreement with the User;
(ii) compliance with the statutory requirements.
6. Personal Data protection
Personal Data is processed by automated means without access of the Organizer’s employees. When applicable, such access may be granted only to the employees that need the Personal Data to perform their tasks. All the employees follow binding internal rules and procedures for Personal Data processing and observe all the technical and organizational security measures to protect and ensure confidentiality of Personal Data.
7. Third parties
The Organizer may transfer Personal Data to third parties not employed by the Organizer for the purposes indicated in Section 5 of the Policy.
Such third parties may include:
(i) partners, foundations, credit and financial institutions, etc.;
(ii) information service providers or consultants of the Organizer;
(iii) national and/or international regulatory bodies, law enforcement agencies, central or local executive bodies, other official or public agencies or courts when Personal Data transfer is necessary as a matter of applicable law or regulation upon appropriate request;
(iv) third parties when Personal Data transfer is necessary for providing the User with a relevant Service, and/or access to the Website, or fulfilling an agreement or contract with the User.
(v) third party when Personal Data transfer is necessary to defend legal rights of the Organizer or third parties in case of an actual or potential violation by the User of the Organizer’s User agreement and/or Policy.
8. Storage and processing of Personal Data
The Organizer stores the User’s Personal Data in the territory of the Russian Federation.
The Organizer records, organizes, accumulates, stores, validates (updates, alters), retrieves personal data by means of databases located in the Russian Federation.
When the User resides in another jurisdiction (outside the Russian Federation) and Personal Data may be transferred to the Organizer only upon a separate agreement, then use of the Website or Services is deemed as confirmation of entering into all necessary agreements for such Personal Data transfer, storage and/or processing obtained in other jurisdiction.
9. Personal Data storage period
The Organizer stores Personal Data no longer than is necessary for the realization of the goals it was gathered for or required by applicable law.
10. Rights of User
If provided by applicable law, the User has the right to:
- Erasure of Personal Data, in whole or in part, and withdrawal of his or her consent for Personal Data processing;
- Restriction of Personal Data processing;
- Object to Personal Data processing, if such right is provided by applicable law.
11. Policy changes
The Organizer reserves the right to unilaterally change the Policy from time to time, including but not limited to, to comply with amendments to applicable law and in the case of changes in the Website and Services.