Privacy policy

PRIVACY POLICY

 

Moscow August 22, 2018

 

 

This Personal Data Privacy Policy (hereinafter referred to as the Privacy Policy), publicized on the domain name https://www.pnkgroup.ru, applies to all information that the company OOO Project-Development (hereinafter referred to as the Company-Operator) may collect about the User during their use of the website at https://www.pnkgroup.ru/, or of the programs or products of the Company.

 

This Privacy Policy has been executed in accordance with Clause 2 Article 18.1 of the Federal Law of the Russian Federation “On Personal Data” No. 152-FZ dated 27 July 2006, as well as with any and all other applicable regulatory legal acts of the Russian Federation in the area of personal data protection and processing, and shall apply to all personal data (hereinafter referred to as data), which the Company may collect from the personal data subject – the Internet user – in the process of the use of any websites, services, programs, or products of the Company.

 

1. TERMINOLOGY

 

1.1. The following terms shall be used in this Privacy Policy:

1.1.1. “Operator (Company)” – the company, which processes personal data and determines the purposes of the personal data processing, the composition of the personal data to be processed, and the actions (operations) performed with personal data;

1.1.2. "Company Website Administration (hereinafter referred to as Website Administration) – the employees acting on behalf of the company, who are authorized to manage the website, and who manage and/or carry out the processing of personal data, as well as determine the purposes of the personal data processing, the composition of the personal data to be processed, and the actions (operations) performed with the personal data.

1.1.3. “Personal data” – any information referring directly or indirectly to a particular or identified individual (personal data subject).

1.1.4. "Personal data processing" – any action (operation) or a combination of actions (operations) performed both automatically and manually with personal data, including collection, recording, arrangement, accumulation, storage, specification (updating, changing), extraction, use, distribution (including transfer), anonymizing, blocking and destruction of personal data.

1.1.5. “Confidentiality of personal data” – the mandatory requirement to the Operator or another party, which has obtained access to personal data, to prevent the dissemination of any such data without the consent of the personal data subject or other legitimate grounds.

1.1.6. “Provision of personal data” – the actions, which aim to make the data available to a definite person or a definite range of persons;

1.1.7. “Dissemination of personal data” – the actions, which aim to disclose personal data to an indefinite range of persons;

1.1.8. “Blocking of personal data” – a temporary cessation of the processing of personal data (with the exception of the cases, when such processing is required for personal data specification);

1.1.9. “Destruction of personal data” – the actions performed on the personal data contained in the respective database, which prevent such data from being restored and/or the actions aimed at the physical destruction of the material media of the personal data;

1.1.10. “Anonymization of personal data” – the actions performed on personal data that do not permit the identity of the individual concerned to be verified solely from such anonymized data;

1.1.11. “Personal Data Information System” – a database, which contains personal data as well as the hardware and software used for data processing;

1.1.12. “User of the Company’s Website (hereinafter referred to as the User) – a person, which has access to the Website via the Internet and using the Company’s Website.

1.1.13. “Cookies” – a small piece of data sent by a web server and stored on the user's computer, which is sent to the web server by the web client or web browser in an HTTP request each time, when requesting to open a page of the corresponding website.

1.1.14. "IP-address" – a unique network address in a computer network built on the Internet Protocol.

 

2. GENERAL PROVISIONS

 

2.1. The use of the Company’s website shall constitute acceptance by the User of this Privacy Policy and the terms of processing of the personal data of the User.

2.2. If the User does not agree with the terms of the Privacy Policy, the User must cease the use of the Company's Website. The Company shall not be liable if the User disagrees with the terms of the Privacy Policy of the Website, but continues to use the Website.

2.3. This Privacy Policy applies only to the Website of the Company. The Company does not control and is not responsible for the websites of third parties, to which the User can be redirected through the links available on the Company's website.

2.4. The Website Administration does not verify the accuracy of personal data provided by the User of the Company's website. The Company shall not be liable for any inaccurate data provided by the User of the Company's website.

 

3. SUBJECT OF THE PRIVACY POLICY

 

3.1. This Privacy Policy establishes the obligations of the Administration of the Company’s website to ensure non-disclosure and the protection of privacy of the personal data, which the User provides upon the request of the Administration of the Company’s website when submitting a request on the Company’s website or when contacting the Company.

3.2. The personal data allowed for processing under this Privacy Policy is provided by the User by filling out the application form on the Company's Website in the "Send request" section and shall include the following information:

3.2.1. Username;

3.2.2. telephone number of the User;

3.2.3. email address of the User;

3.2.4. subject of the request;

3.2.5. comment;

3.3. The company shall protect the following Data, which is transmitted automatically when the User views advertising blocks or visits the pages with the integrated statistical script of the system ("pixel"):

3.3.1. Disabling cookies may make it impossible to access the parts of the Company's website, which require authorization.

3.3.2. The company collects statistics on the IP-addresses of the visitors. This information shall be used to identify and solve technical issues.

3.4. The Company shall ensure the safe storage and non-dissemination of any other personal information additional to that specified above (browsers and operating systems used, etc.), with the exception of the cases identified in clauses 5.2 and 5.3 of this Privacy Policy.

 

4. PURPOSES OF COLLECTION OF THE PERSONAL DATA OF THE USER

 

4.1. The Administration of the Company’s website may use the User’s personal data for the following purposes:

4.1.1. identifying the User who has sent a request through the Company's website;

4.1.2. providing access to the User’s personalized resources of the Company's Website;

4.1.3. contacting the User, including sending notifications, as well as inquiries regarding the use of the Company's Website, the delivery of services, and the processing of the User’s requests;

4.1.4. determining the location of the User to ensure security and to prevent fraud;

4.1.5. confirmation of the accuracy and completeness of the personal data provided by the User;

4.1.6. notifying the User of the Company’s Website about the status of their Requests;

4.1.7. providing the User with effective customer and technical support in the event of problems related to the use of the Website;

4.1.8. providing the User, given their consent, with special offers, information on prices, newsletters and other information on behalf of the Company or on behalf of the Company's partners;

4.1.9. advertising activities, given the consent of the User;

4.1.10. providing access to the websites or services of the Company's partners in order to make products, updates, and services available to the User.

 

5. METHODS AND TERMS FOR PROCESSING PERSONAL DATA

 

5.1. The processing of the User’s personal data shall be carried out without any limitations in time and by any legitimate means, including in personal data information systems with or without automation tools.

5.2. The User agrees that the Website Administration has the right to transfer personal data to third parties, in particular, courier services, postal service organizations, telecommunications operators, solely for the purpose of fulfilling the User’s request made on the Company's Website.

5.3. The personal data of the User may be transferred to the Russian government authorities with correspondent jurisdiction only on the basis of the grounds and in accordance with the procedure established by the legislation of the Russian Federation.

5.4. In event of loss or disclosure of personal data, the Website Administration shall inform the User about the fact of loss or disclosure of their personal data.

 

6. OBLIGATIONS OF THE PARTIES

 

6.1. The User shall be obliged as follows:

6.1.1. To provide the information about their personal data required for the use of the Company Website and for submitting a request.

6.1.2. To update and supplement the information provided on their personal data in the event that such information changes, in order for their request submitted to the Company to be processed correctly.

 

6.2. The website administration shall be obliged as follows:

6.2.1. To use the information obtained solely for the purposes specified in this Privacy Policy.

6.2.2. To ensure the protection of the confidentiality of the information stored, to not disclose the personal data submitted by the User without their prior written permission, as well as to not sell, exchange, publish, or disclose such data in any other possible way, with the exception of the cases specified in clauses p. 5.2 and 5.3 of this Privacy Policy.

6.2.3. To take precautions to protect the confidentiality of the User’s personal data in accordance with the procedure commonly used to protect such types of information in current business practice.

6.2.4. To perform the blocking of the personal data related to the User for the duration of an investigation, upon the request of the User, their legal representative, or the authorities with jurisdiction over the protection of the rights of personal data subjects, in the event that inaccurate personal data or any illegal acts have been discovered.

 

7. LIABILITIES OF THE PARTIES

 

7.1. In the event that the Website Administration does not fulfill their obligations, they shall be liable for the losses incurred by the User in connection with the unlawful use of their personal data, in accordance with Russian law, with the exception of the cases specified in clauses p. 5.2, 5.3, and 7.2 of this Privacy Policy.

7.2. In the event of loss or disclosure of the Confidential Information, the Website Administration shall not be liable in the following conditions:

7.2.1. such confidential information became available to the public prior to its loss or disclosure;

7.2.2. such confidential information was received from a third party prior to its receipt by the Website Administration;

7.2.3. such confidential information was disclosed with the consent of the User.

 

8. DISPUTES

 

8.1. Prior to filing a lawsuit in disputes, arising from the relations between the User of the Company Website and the Website Administration, it is mandatory to present a claim (a written proposal of a voluntary resolution of the dispute) to the other party.

8.2. Within 30 calendar days from the date of receipt of the claim, the recipient shall notify the claimant in writing of the results of the investigation of the claim. The claims shall be sent to the address indicated on the Company's website.

8.3. If an agreement cannot be reached, the dispute shall be submitted to the judicial authority in accordance with the current legislation of the Russian Federation.

8.4. The current legislation of the Russian Federation applies to this Privacy Policy and the relationship between the User and the Website Administration.

 

9. SUPPLEMENTARY PROVISIONS

 

9.1. The Website Administration shall have the right to amend this Privacy Policy without the consent of the User. The amendments shall be published on the Company's Website as a New Edition of the Privacy Policy.

9.2. The New Edition of the Privacy Policy shall enter into force from the moment of its publication on the Company's Website, unless otherwise provided by the New Edition of the Privacy Policy.

9.3. All suggestions and questions about this Privacy Policy should be communicated via the contact form on the Company's Website. The User shall receive clarifications on any issues relating to the processing of their personal data by contacting the Operator via the Company's email.

9.4. The current Privacy Policy has been published at https://www.pnkgroup.ru/en/privacy.

 

 

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