Политика конфиденциальности ООО «Крестецкая строчка» Gift

CONFIDENTIALITY POLICY OF KRESTETSKAYA STROCHKA LIMITED LIABILITY COMPANY

This Personal Data Confidentiality Policy (hereinafter “Confidentiality Policy”) applies in respect of all information which the KRESTETSKAYA STROCHKA Limited Liability Company (hereinafter the “Company” or the KRESTETSKAYA STROCHKA LLC) with the domain name of the basic information resource www.krstrochka.ru (hereinafter the “Website”) may obtain about the User while using the Website.

TERMS AND DEFINITIONS

1.1. This Confidentiality Policy makes use of the following terms:

1.1.1. “Website administration” (hereinafter the “Administration”) is the personnel authorized to carry out the website management and acting on behalf of the KRESTETSKAYA STROCHKA LLC, who arrange and/or carry out personal data procession, as well as determine the purpose of its procession, the contents of the personal data to be processed, actions (operations) performed with respect to personal data.

1.1.2. Personal data is represented by any information directly or implicitly related to a definite or identifiable natural person (subject of personal data).

1.1.3. Personal data processing is any action (operation) or a series of actions (operations) performed with personal data by means of automatic facilities or without the latter including collection, recording, systematization, accumulation, storage, adjustment (updating, alteration), retrieval, use, transmission (distribution, supplying, access), depersonalization, blocking, deleting, destruction of personal data.

1.1.4. Personal Data Confidentiality is the obligatory requirement to be observed by the Website Administration or any other person who had been granted access to personal data, which consists in preventing their distribution without the consent of the subject of the personal data or the existence of any other legal grounds.

1.1.5. The Website user (hereinafter the User) is a person having access to the Website through the Internet network and using the Company’s Website.

1.1.6. Cookies is a small data segment sent by the web server and stored in the User’s computer, which is sent by a web client or web browser to the web server in a HTTP-request every time there is an attempt to open the respective website page.

1.1.7. IP address is a unique host web address in the IP protocol-based computer network.

GENERAL PROVISIONS

2.1. Using the Website www.krstrochka.ru by the User means agreement with this Confidentiality Policy and with the terms and conditions of the User’s personal data processing.

2.2. In the event of disagreement with the terms and conditions of the Confidentiality Policy the User is to stop using the Website.

2.3. This Confidentiality Policy applies in respect of www.krstrochka.ru only. KRESTETSKAYA STROCHKA LLC neither controls nor bears responsibility for third persons’ websites, which can be accessed by the User through the available links at www.krstrochka.ru.

2.4. The Website Administration does not verify the personal data submitted by the Website User for correctness.

OBJECT OF THE CONFIDENTIALITY POLICY

3.1. This Confidentiality Policy sets forth the responsibilities of the Website Administration concerning non-disclosure of personal data and ensuring confidentiality protection mode in respect of the personal data submitted by the User upon request of the Website Administration when filling in the Feedback Form at www.krstrochka.ru.

3.2. Personal Data approved for processing in the framework of this Confidentiality Policy are to be submitted by the User by filling in the Feedback Forms that include the following information:

3.2.1. The User’s name and surname;

3.2.2. The User’s phone number;

3.2.3. E-mail address;

3.2.4. Name of the company on whose behalf the User acts;

3.2.5. City/ Region where the company is located.

3.3. The company is to protect personal data, which are automatically transmitted while viewing advertising blocks and when browsing the pages that lead to www.krstrochka.ru and that bear the statistical system script (“pixel”): IP address; information from cookies; information about browser (or some other program that provides access to showing advertisements); access time; the address of the page where the advertisement block is located; referrer (the address of the previous page).

3.3.1. Disabling cookies may bring about the impossibility of access to some parts of the Website.

3.3.2. The company collects statistical data about its visitors’ IP addresses. This information is used for trouble shooting and elimination.

PURPOSE OF THE USER’S PERSONAL DATA COLLECTION

4.1. The User’s personal data may be used by the Company’s Website Administration with the purpose of:

4.1.1. User identification and furnishing reference information, consulting as regards the Company’s goods and services.

4.1.2. Establishing feedback with the User, including forwarding notifications, inquiries in respect of using the Website, providing services, processing the User’s inquiries and requests.

4.1.3. Determining the User’s location to ensure safety and prevent scam.

4.1.4. Confirming reliability and completeness of the personal data submitted by the User.

4.1.5. Offering effective client and technical support to the User in case of troubles connected with using the Website, the Company’s goods or services.

4.1.6. Offering to the User, based on his prior consent, information updates on products and services, special offers, information about prices, newsflashes and other data on behalf of the Company.

4.1.7. Engaging in advertising activity with the User’s consent.

METHODS AND PERIODS OF PERSONAL DATA PROCESSING

5.1. Personal data processing is performed without limitation of the period, by any legal method, including personal data information systems with or without the application of automation facilities.

5.2. The User agrees that the Website Administration is entitled to transfer personal data to third persons, particularly, to courier services, postal organizations, telecommunications operators, with the sole purpose of the User’s order execution, including Goods delivery and document flow.

5.3. The User’s personal data may be transferred to the authorized governmental bodies of the Russian Federation only on the grounds stated in the law of the Russian Federation and in accordance with the established procedure.

5.4. In case of the User’s personal data loss or disclosure the Website Administration informs the User of the said personal data loss or disclosure.

5.5. The Website Administration takes the required arrangements and technical precautions for protecting the User’s personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, dissemination, as well as from other illegal acts by third parties.

5.6. The Website Administration, jointly with the User, takes all the required measures for preventing losses or other adverse effects caused by the User’s personal data loss or disclosure.

RESPONSIBILITIES OF THE PARTIES

6.1. The User is obliged to:

6.1.1. Submit reliable information regarding his personal data required in order to use the Company’s Website.

6.2. The Website Administration is obliged to:

6.2.1. Use the obtained information only for the purposes specified in item 4 of this Confidentiality Policy.

6.2.2. Ensure keeping confidential information under the seal of secrecy, not disclosing it without the User’s prior written consent, as well as refrain from selling, exchange, publishing or disclosing the User’s submitted personal data by other possible methods, with the exception of items 5.2 and 5.3 of this Confidentiality Policy.

6.2.3. Take precautions for protection of the User’s personal data confidentiality in accordance with the procedure which is usually used to protect this kind of information in the existing business exchange.

6.2.4. Block the personal data related to the respective User from the moment of application or inquiry filed by the User, his legal representative or the authorized body for protection of the rights of subjects of personal data for the period of inspection, in case of finding unreliable personal data or illegal acts in accordance with Article 21 of the Federal Law “On Personal Data” dated 27.07.2006 N 152-ФЗ.

LIABILITY OF THE PARTIES

7.1. The Website Administration that has failed to fulfill its responsibilities shall be held liable for the losses incurred by the User in connection with illegal use of personal data in accordance with the law of the Russian Federation, with the exception of the cases specified in items 5.2., 5.3. and 7.2. of this Confidentiality Policy.

7.2. In the event of Confidential information loss or disclosure, the Website Administration shall not be held liable if this Confidential information:

7.2.1. Became public prior to its loss or disclosure.

7.2.2. Was obtained by the Website Administration from a third party prior to its submission by the User. 7.2.3. Was disclosed with the User’s consent.

DISPUTE RESOLUTION

8.1. Prior to filing a court action concerning disputes arising out of the relations between the Website User and the Website Administration, it is obligatory to submit a claim (written proposal of voluntary dispute settlement).

8.2. The party receiving the claim shall notify the claimant on the results of the claim consideration within 30 calendar days as of the date of receiving the claim.

8.3. In case of failure to come to an agreement, the dispute may be transferred to a judicial authority for consideration in accordance with the applicable law of the Russian Federation.

8.4. This Confidentiality Policy and the relations between the User and the Website Administration are governed by the applicable law of the Russian Federation.

ADDITIONAL PROVISIONS

9.1. The Website Administration is entitled to amend this Confidentiality Policy without the User’s consent.

9.2. New Confidentiality Policy becomes effective from the moment of its placement at the Company’s Website, unless stipulated otherwise in the updated version of the Confidentiality Policy.

9.3. All suggestions or questions related to this Confidentiality Policy are to be sent to this e-mail address: info@krstrochka.ru, where the “RE” section should be worded as KRESTETSKAYA STROCHKA LLC Confidentiality Policy.

9.4. The applicable Confidentiality policy has been posted on the Website of KRESTETSKAYA STROCHKA