“30” July 2021
1. General
1.1. This privacy policy (hereinafter referred to as the Policy) is a policy of the Autonomous non-profit organisation “ROSGONKI” (ANO “ROSGONKI”), PSRN: 1177700021388, located at 13 Barklaya St., Bldg. 2, 3rd Floor, Office 1, Moscow 121309 (hereinafter referred to as the Website Owner).
1.2. In the Rosgonki Website Privacy Policy (hereinafter referred to as the Policy) the following definitions apply:
User means a person using the Website and providing his/her Personal Data in the manner prescribed by this Policy.
Website means an information system belonging to the Website Owner, consisting of a set of graphic and information materials, as well as programme code and databases ensuring the availability of such materials on the Internet at https://www.rosgonki.ru/.
Personal Data means any information relating directly or indirectly to a specific or identifiable person, including contact information (full name, phone number, email address); data that is automatically transmitted to the services of the Website in the course of their use with the software installed on the User’s device, including the IP address, cookie data, information about the User’s browser, technical characteristics of the equipment and software used by the User, date and time of access to the Website, its services and other similar information.
Provision of Personal Data means actions taken by the User to disclose Personal Data to the Website Owner when performing actions on the pages of the Website and its services.
1.3. The Policy applies to all Personal Data received by the Website Owner.
1.4. The use of the Website by the User means acceptance of this Policy and the terms of the processing of the User’s Personal Data. If he/she disagrees with the terms of the Policy, the User must leave the Website.
1.5. The purpose of the Policy is to ensure adequate protection of the Users’ Personal Data from unauthorised access and disclosure.
1.6. Consent to the processing of Personal Data provided by the User himself/herself is expressed by the User by
performing actions on the Website (by putting ticks in the relevant webform).
1.7. Consent to the processing of Personal Data automatically collected by the Website Owner is expressed by responding in the form provided on the Website during the User’s first and subsequent openings of the Website.
1.8. The Website Owner ensures the accuracy and safety of the processed Personal Data. The User has the right to clarify his/her Personal Data if the Personal Data is incomplete, outdated, inaccurate or not necessary for the stated purpose of the processing. The User has the right to receive information regarding the processing of his/her Personal Data (except for publicly available information).
1.9. When processing Personal Data, the Website Owner, acting reasonably and in good faith, believes that the User:
• has all the necessary rights to allow him/her to provide Personal Data and use the Website;
• acts voluntarily, in his/her own interests or based on existing powers;
• provides reliable information in the amount necessary to provide him/her with services on the Website;
• has read and understood the Policy.
1.10. The Website Owner, complying with the requirements of Federal Law of the Russian Federation No. 152-FZ “On Personal Data” dated 27/07/2006, makes this Policy publicly available on the Website.
1.11. If the User gives the relevant consent, his/her Personal Data may be made publicly available.
2. Personal Data Processing Principles and Terms
2.1. Personal Data is processed by the Website Owner based on the following principles:
• legality
• processing of Personal Data being limited to the achievement of specific, predetermined, and legitimate goals;
• prevention of the processing of Personal Data that is incompatible with the purposes of the collection of the Personal Data;
• prevention of databases containing Personal Data, the processing of which is carried out for purposes incompatible with each other, getting combined;
• processing of only that Personal Data that meets the purposes of their processing;
• compliance of the content and amount of the processed Personal Data with the stated purposes of the processing;
• prevention of the processing of Personal Data that is redundant for the stated purposes of their processing;
• ensuring of the accuracy, sufficiency, and relevance of Personal Data in relation to the purposes of the processing of Personal Data;
• ensuring the proper storage of Personal Data;
• destruction or depersonalisation of Personal Data upon achievement of the goals of their processing or in case there is no need to achieve these goals anymore.
2.2. The Website Owner processes Personal Data if at least one of the following conditions is met:
• the Personal Data is processed with the consent of the subject of the Personal Data to the processing of his/her Personal Data;
• the processing of the Personal Data is necessary for the administration of justice, the execution of a court ruling, an act of another body or official, subject to execution in accordance with the law of the Russian Federation on enforcement proceedings;
• the processing of the Personal Data is necessary for the performance of an agreement/offer, to which the subject of the Personal Data is either a party, a beneficiary, or a guarantor, as well as for the conclusion of an agreement at the initiative of the subject of the Personal Data or an agreement under which the subject of the Personal Data will be a beneficiary or guarantor;
• the processing of the Personal Data is necessary to exercise the rights and legitimate interests of the Website Owner or third parties or to achieve socially significant goals, if this does not violate the rights and freedoms of the subject of the Personal Data;
• the Personal Data to which the subject of the Personal Data has provided access to an unlimited number of persons or this access has been provided at his/her request is being processed (hereinafter referred to as publicly available personal data);
• the processing of the Personal Data that is subject to publication or mandatory disclosure in accordance with a federal law.
2.3. The Website Owner shall ensure the confidentiality of the Personal Data that is not publicly available. The Website Owner who has gained access to Personal Data shall not disclose it to third parties and shall not distribute the Personal Data that is not publicly available without the consent of the subject of the Personal Data, unless otherwise provided for by a federal law.
3. Users’ Personal Data Collection and Processing Purposes
3.1. The Website Owner collects, uses and stores only that Personal Data that is necessary for the provision of services and/or that the User has himself/herself decided to disclose to the Website Owner, namely for the following purposes:
• the identification of Users when they use the Website, its services;
• the provision of services to a User;
• communication with a User, processing his/her requests and applications, sending notifications and information regarding the use of the Website;
• the improvement of the quality of services provided, ease of use, development of new services;
• targeting of advertising materials;
• sending of newsletters and advertising information;
• the receipt of feedback from a User, including sending of notifications, requests regarding the use of the Website, the provision of services, processing of requests and applications from the User;
• statistical and other studies based on anonymised data.
3.2. The processing of Personal Data for other purposes is not allowed, unless the User expresses specific, informed, and conscious consent to such processing.
4. Terms of User’s Personal Data Processing and Transfer to Third Parties
4.1. When processing Personal Data, the Website Owner is guided by Federal Law of the Russian Federation No. 252-FZ “On Personal Data” dated 27 July 2006. Regarding Personal Data, its confidentiality is preserved, except for cases when a User voluntarily provides information about himself/herself for general use to an unlimited number of persons (public data).
4.2. The Website Owner has the right to use Personal Data for the purposes specified in clause 3.1. of this Policy.
4.3. The Website Owner is not entitled to transfer the Personal Data of Users that is not publicly available to third parties, except if such transfer is necessary for the purpose of the performance of an agreement/offer concluded between the User and the Website Owner and the relevant consent of the User has been obtained.
4.4. The User has the right to withdraw his/her consent to the processing of his/her Personal Data at any time. In this case, the Website Owner stops processing the Personal Data and, if the storage of the Personal Data is not required for the purposes of complying with the law of the Russian Federation, destroys the Personal Data or undertakes to ensure its destruction, unless otherwise provided for by an agreement between the Parties. To withdraw his/her consent to the processing of his/her Personal Data, a User has the right to send the relevant request to the email address: info@rosgonki.ru.
4.5. The Personal Data is processed without any time limit, in any legal way, including in personal data information systems using automation tools or without using such tools.
4.6. The Website Owner protects Personal Data that is automatically transmitted when the Website is visited:
- IP address;
- information from cookies;
- browser information
- access time;
- referrer (address of the previous page).
Disabling cookies may result in parts of the Website that require authorisation becoming inaccessible.
4.7. The Website Owner has the right to collect statistics on the IP addresses of its visitors. This information is used to prevent, detect, and solve technical problems.
5. User’s Personal Data Protection
5.1. The Website Owner takes the necessary and sufficient organisational and technical measures to protect the User’s Personal Data from unauthorised or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.
6. Dispute Resolution
6.1. Before taking legal action in respect of the relationship between a User and the Website Owner, a claim (a written proposal for a voluntary settlement of the dispute) needs to be made.
6.2. The recipient of the claim within 10 business days of the date of the receipt of the claim shall notify the author of the claim in writing about the results of the consideration of the claim.
6.3. If an agreement is not reached, the dispute may be referred to a judicial authority in accordance with the current law of the Russian Federation.
7. Policy Amendments and Applicable Law
7.1. The Website Owner has the right to amend this Privacy Policy without notifying Users. The new version comes into force when it is posted on the Website.
7.2. The Policy and relations between the Website Owner and a User are subject to the law of the Russian Federation, unless otherwise provided for in an agreement between the Website Owner and the User.
7.3. Please send any suggestions or questions regarding this Policy to the email address: info@rosgonki.ru.
FORM
Consent to Processing of Personal Data for Rosgonki Website
By leaving any request on the website at https://www.rosgonki.ru/ (hereinafter referred to as the Website), the User accepts this Consent to Processing of Personal Data (hereinafter referred to as the Consent). Acting freely, willingly and for his/her own benefit, as well as confirming his/her legal capacity, the User grants his/her consent in accordance with the requirements of Article 9 of Federal Law No. 152-FZ “On Personal Data” dated 27 July 2006 to Autonomous non-profit organisation “ROSGONKI”, registered address: 13 Barklaya St., Bldg. 2, 3rd Floor, Office 1, Moscow 121309
(hereinafter referred to as ROSGONKI), for the processing of his/her personal data, including last name, first name, patronymic, sex, date of birth, address of registration, address of residence, contact phone number, email address, passport data.
The purpose of the processing of the personal data: the processing of the person’s incoming requests to provide advice, the analytical data of the actions of the person on the Website and the operations of the Website; the sending of advertising emails and newsletters, data analysis for commercial purposes; the ordering of any services through the Website.
The User confirms that his/her personal data is publicly available.
The User grants ROSGONKI the right to transfer his/her personal data to ROSGONKI’s officials, ROSGONKI’s partners and contractors for the above purposes.
He/she grants ROSGONKI the right to carry out any activities (operations) with his/her personal data, including collection, systematisation, accumulation, storage, updating, amending, use, data masking, blocking and destruction. ROSGONKI shall have the right to process the User’s personal data by inputting it into the electronic database, including it into the lists (registers) and report forms, in accordance with the documents, regulating ROSGONKI’s operations. This consent shall be valid for 3 (three) years from the date when it is granted.
The User reserves the right to recall his/her consent by making a request in writing, which he/she can mail to ROSGONKI as an email, a registered letter with an acknowledgement of service or which can be services directly to ROSGONKI’s authorized representative subject to an acknowledgement of receipt.
The processing of the personal data shall be terminated within 3 (three) days of receipt by ROSGONKI of the request (recall) in writing and/or once the objective of the processing is achieved and shall be destroyed within the period and on conditions as established by law, unless otherwise specified.