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Policy of personal data processing and confidentiality of personal information

1. General Provisions

1.1. This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of July 27, 2006. No. 152 “On Personal Data” and determines the procedure for processing personal data and measures to ensure the security of personal data taken by the Joint-stock company «WestLink Group».

1.2. The operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and a citizen in the processing of his personal data, including the protection of the rights to privacy, personal and family secrets.

1.3. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can receive about visitors to the website.

1.4. Using the services of the Site means the User's unconditional consent to this Policy and the conditions for processing his personal information specified therein; in case of disagreement with these conditions, the User must refrain from using the Site.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data - processing of personal data using computer technology.

2.2. Blocking of personal data is a temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data).

2.3. Site - a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address:

2.4. Information system of personal data - a set of personal data contained in databases and information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other subject of personal data.

2.6. Personal data processing - any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator – JSC «WestLink Group», TIN 9705074872, OGRN 1167746815720.

2.8. Personal data - any information relating directly or indirectly to a specific or identifiable User of the Site.

2.9. User - any visitor to the Site.

2.10. Providing personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.

2.11. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing with personal data of an unlimited number of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way.

2.12. Destruction of personal data - any actions as a result of which personal data is destroyed irretrievably with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) material carriers of personal data are destroyed.

3. Processing of personal data

3.1. The Operator may process the following personal data and information of the User:
- name;
- email address;
- phone number;
- data that is automatically transmitted to the services of the Site in the course of their use using the software installed on the User's device, including IP address, cookie data, information about the User's browser (or other program that accesses the services), technical characteristics of the equipment and software used by the User, date and time of access to the services, addresses of the requested pages and other similar information.

3.2. The above data further in the text of the Policy are united by the general concept of "personal data".

3.3. In relation to the specified in paragraph 3.1. User information is kept confidential.

4. Purposes of personal data processing

4.1. The purposes of processing the User's personal data: informing the User by sending emails; providing the User with access to the services, information and / or materials contained on the Site. The Operator collects and stores only that personal information provided by the User, which is necessary for the provision of services or the execution of agreements and contracts with the User, except when the law provides for the mandatory storage of personal information for a period specified by law.

4.2. Anonymized data of Users collected using Internet statistics services are used to collect information about the actions of Users on the Site, improve the quality of the Site and its content.

4.3. From time to time, as part of the use of this Site, in order to gain access to certain data, to participate in events, surveys or to exchange information on topics of interest to the User, personal information may be required. In such cases, the personal data provided will be used to process the User's request, as well as to customize / upgrade the Site and the corresponding services offered. The Administrator may process personal data for marketing purposes and send to the User information materials relating to the scope of the Website Administration, or promotional materials and information regarding the services offered by WestLink Group of Companies JSC and the partners of the company, which may be of interest to User. The Operator may contact Users in order to obtain feedback on the services provided, as well as to conduct marketing and other research.

5. Legal grounds for the processing of personal data

5.1. The Operator processes the User's personal data only if they are filled in and / or sent by the User independently through special forms located on the Site. By filling out the relevant forms and / or sending their personal data to the Operator, the User expresses his consent to this Policy.

5.2. The Operator processes anonymized data about the User if it is allowed in the User's browser settings (saving cookies and using JavaScript technology is enabled).

6. The procedure for collecting, storing, transferring and other types of processing of personal data

6.1. The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

6.2. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.

6.3. The term for processing personal data is unlimited. The User may at any time withdraw his consent to the processing of personal data by sending the Operator a notification by e-mail to the Operator's email address marked "Withdrawal of consent to the processing of personal data". The processing of personal data of Users is carried out in accordance with the Federal Law of July 27, 2006 N 152 "On Personal Data".

7. Obligations of the parties

7.1. The Site Administration is obliged to use the information received solely for the purposes specified in this Privacy Policy; to 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 in other possible ways the transferred personal data of the User, except as provided for in this Privacy Policy.

7.2. The Site Administration is obliged to take precautions to protect the confidentiality of the User's personal data, in accordance with the procedure usually used to protect this kind of information in existing business transactions.

7.3. The Site Administration is obliged to block personal data relating to the relevant User from the moment the User or his legal representative or an authorized body for the protection of the rights of personal data subjects has applied or requested for the period of verification in case of revealing false personal data or illegal actions.

8. Liability of the parties

8.1. In case of loss or disclosure of confidential information, the Operator is not responsible if this confidential information: became public domain before its loss or disclosure; was received from a third party prior to its receipt by the Operator; was disclosed with the consent of the User.

9. Dispute Resolution

9.1. Before going to court with a claim on disputes arising from the relationship between the User and the Operator, it is mandatory to submit a claim (a written proposal for voluntary settlement of the dispute), which must be considered within 30 (thirty) calendar days from the date of receipt of the claim.

9.2. If an agreement is not reached, the dispute will be referred to the court in accordance with the current legislation of the Russian Federation.

10. Additional terms

10.1. The Site Administration has the right to make changes to this Privacy Policy without the consent of the User.

10.2. The new Privacy Policy comes into force from the moment it is posted on the Site, unless otherwise provided by the new edition of the Privacy Policy.

10.3. The policy is valid indefinitely until it is replaced by a new version.

10.4. The User may revoke previously issued consents by sending a corresponding message to the e-mail address of the Site Administration: