Personal Data Processing and Protection Policy of the Website

Pavlovsky Posad
October 1, 2018

 1. The User shall fully read this Policy before registering on the Website. User registration on the Website means full and unconditional acceptance of this Policy by the User in accordance with article 438 of the Civil Code of the Russian Federation.
2. By accepting this Agreement by registering on the Website, the User confirms that he/she is familiar with this Policy, and thereby expresses his/her informed and conscientious consent to it and to the processing of personal data provided during registration by the Holder of a copyright, as well as placed by the User voluntarily on his/her personal page.
2.1. The Site Administration proceeds on the assumption that when providing personal data on the Website, the User is a competent person. In case of incapacity of such a person, consent to the processing of personal data is provided by the legal representative of the User who has read and agrees to the terms of processing of personal data specified in this Policy.
3. Processing of personal data is any action (operation) or a set of actions (operations) performed on personal data using automation tools or without their use. The processing of personal data includes:
● collection;
● record;
● systematization;
● accumulation;
● storage;
● refinement (update, change);
● extraction;
● use;
● transfer (distribution, provision, access);
● depersonalization;
● blocking;
● deletion;
● destruction.
● automated processing of personal data is processing of personal data using computer
● distribution of personal data is actions aimed at disclosure of personal data to an
indefinite scope of persons;
● provision of personal data is actions aimed at disclosure of personal data to a certain
person or a certain scope of persons;
● blocking of personal data is temporary termination of personal data processing (except
in cases when processing is necessary to clarify personal data);

● destruction of personal data is actions as a result of which it becomes impossible to
restore the content of personal data in the information system of personal data and (or)
as a result of which tangible media of personal data are destroyed;
● depersonalization of personal data is actions that make it impossible to determine the
ownership of personal data to a personal data owner without the use of additional
● personal data information system is a set of personal data contained in databases and
information technologies and technical means ensuring their processing;
● trans-border transfer of personal data is transfer of personal data to the territory of a
foreign state to the authority of a foreign state, a foreign individual or a foreign legal
● access to data is the ability to obtain information and use it;
● confidentiality of data is a mandatory requirement for a person who has access to
certain information not to transfer such information to third parties without the consent
of its owner;
● provision of data is actions directed to obtaining of information by certain persons or
information transfer to a certain number of persons,
● dissemination of data is actions aimed at obtaining information by an indefinite
number of persons or transferring information to an indefinite number of persons;
● data owner is a person who independently created the information or received on the
basis of law or contract the right to allow or restrict access to information determined
on any grounds.
4. Within the framework of this Policy, the User personal data is understood as:
4.1. Personal data that the User provides about himself/herself when registering on the Website.
4.2. Data that are automatically transferred to the Holder of a copyright in the process of using the Website with the help of software installed on the user’s device, including IP-address, information from cookies, information about the user’s browser (or other program that allows access to the Website services), access time, address of the requested page, as well as other data, including those reported by the User after the User registration, when using the Website.
5. This Policy applies only to the services of the Website. The Holder of a copyright does not control and is not responsible for the websites/services of third parties to the pages of which the User can go using the links available on the services of the Website, including the User data processed by third parties.
6. The Holder of a copyright collects and stores only the personal data that is necessary for the provision of the Website services or the execution of agreements and contracts with the User, except in cases where the legislation provides for the mandatory storage of personal data for a certain period of time, including for the purpose of:
- user identification;
- provision of personalized services to the User;

- communication with the User, including sending notifications, requests and information relating to the use of the website, the provision of services, as well as processing requests and applications from the User;
- targeting of advertising materials;
- carrying out statistical and other researches on the basis of impersonal data;
- carrying out marketing actions for Users, including for the purpose of distribution of offers on participation in the promotion and receiving the prizes/rewards provided by the promotion;
distribution of advertising and information materials on telecommunication networks, including by means of telephone, Fax, mobile radiotelephone communication, or by direct contacts; targeting of advertising materials and other information brought to the attention of Users.
7. The user can change (update, supplement) the provided personal data or its part at any time, as well as the parameters of its confidentiality, using the function of editing personal data in the personal account.
8. In respect of the User personal data, its confidentiality is maintained, except in cases of voluntary provision by the User of data about himself/herself for public access to an unlimited number of persons.
9. The Holder of a copyright r has the right to transfer the User personal data to third parties in the following cases:
- the User has expressed his/her consent to such actions;
- transfer is necessary to use a particular service of the Website;
- the transfer is provided for by Russian or other applicable legislation within the procedure established by the legislation;
- the transfer takes place within the framework of the sale or other transfer of the Website (in whole or in part), while the purchaser assumes all obligations to comply with the terms of this Policy in relation to the received personal data.
10. The Holder of a copyright is entitled to:
- maintain processing of personal data, automated processing of personal data, distribution of
personal data, provision of personal data, blocking of personal data, destruction of personal
data, depersonalization of personal data;
- use cookies and similar technologies (including pixel tags, web beacons, transparent GIF
files, JavaScript and local data storage, etc.) to collect personal identifiable information, or
information that may become personal identifiable information in combination with other
data, in compliance with all necessary regulatory requirements regarding the privacy of Users
personal data, by identifying users, counting their number and monitoring which pages of the
Website they visit, to ensure maximum convenience to users, providing personalized data,
remembering preferences in the field of marketing and products, as well as helping to get the

right information (including to enter the protected areas of the website or to use the virtual
shopping cart), analysis of User actions on the Website in order to improve and optimize the
operation of the Website, including to simplify the search of the necessary information on the
- provide advertising, messages and content, including using the distribution of advertising
SMS notifications (messages), advertising notifications and messages via e-mail on the
Internet, using the services and databases of both the Website itself and the services of third-
party (external) sites and resources on the Internet with the provision of the minimum
necessary User personal data to their address.
11. The Holder of a copyright is entitled to use the information provided by the User,
including personal data, in order to ensure compliance with the requirements of the current
legislation (including for the prevention and/or suppression of illegal and/or illegal actions of
Users). Disclosure of the data provided by the User can be made only in accordance with the
current legislation at the request of the court, law enforcement agencies, as well as in other
cases provided by law.
12. Personal data processing is carried out from the moment of registration of the User
account, or the provision of personal data by a person in a different form, and until the
termination of the relationship between the Website administration and the User as a result of
the deletion of his/her account, or withdrawal of consent to the processing of personal data by
the person provided such data in a different form.
13. The User is solely responsible for the security (resistance to selection) of the chosen
means to access the account, as well as independently ensures their confidentiality. The User
is solely responsible for all actions (as well as their consequences) within or using the services
of the Website under the User’s account, including cases of voluntary transfer by the User of
data for access to the User’s account to third parties on any terms (including under contracts
or agreements). In this case, all actions within or using the services of the Website under the
User’s account are considered to be made by the User.
14. All User data posted on the Website is provided directly by the Users. Before placing this
information on the Website, the Administration takes reasonable measures to verify the
information provided to the Website Administration. However, the Website Administration
does not regularly check this information for its relevance. When forming contacts or using
such information, the interested User undertakes to independently verify the accuracy of the
information posted on the Website.
15. The Website may contain links to websites and other information resources of third parties
on the Internet, placed solely for the convenience of Users. The Website Administration does
not declare its approval and does not give any estimates of third party websites or information
contained on these websites, as well as the possible results of their use, and does not verify the
accuracy and relevance of this information. The User is fully responsible for the use of third-
party websites.
16. In case of loss or disclosure of personal data, the Website Administration informs the User
about the loss or disclosure of personal data and sends a notification to the Federal Service for
Supervision in the Sphere of Communications, Information Technology and Mass

17. The Website Administration takes the necessary organizational and technical measures to
protect the User personal data from unauthorized or accidental access, destruction,
modification, blocking, copying, distribution, as well as other illegal actions of third parties.
18. The Website Administration together with the User takes all necessary measures to
prevent losses or other negative consequences caused by the loss or disclosure of the User
personal data.
19. The User is obliged to:
19.1. Provide information on personal data necessary for the use of the website.
19.2. Update, supplement the provided information on personal data in case of changes in this
20. The Website administration is obliged to:
20.1. Use the data obtained only for the purposes specified in this Policy.
20.2. Ensure the storage of confidential information in secret, not to disclose without the prior
written permission of the User, and not to sell, exchange, publish or disclose the transferred
personal data of the User in other possible ways, except for those defined in this Policy.
21. This Policy is an integral part of:
- the Website User Agreement: of October 1, 2018.