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PERSONAL DATA POLICY

1. General provisions

This Personal data policy is compiled in accordance with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by LLC "GRUNWALD" (hereinafter referred to as the Operator).

1.1. The observance of human rights and freedoms is the medium and the ultimate purpose of all actions of the Operator. The same principle applies to personal data processing: the Operator ensures that the rights and freedoms of a citizen shall be observed, including their personal and family privacy.

1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors of the website https://www.grunwald.ru .

2. Basic concepts used in the Policy

2.1. Automated processing of personal data – the personal data processing with the help of computer technology.

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

2.3. Website – collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the Internet address https://www.grunwald.ru .

2.4. The personal data information system – 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 make the data devoid of any information that may allow identification of the specific User or other personal data subject (hereinafter referred to as Data Subject).

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

2.7. Operator – state body, municipal body, legal entity or an individual, that organizes and processes personal data independently or jointly with other persons, and determines the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal data – any information related directly or indirectly to a specific or identifiable User of the website https://www.grunwald.ru/.

2.9. Personal data authorized for distribution by Data Subject – personal data of a Data Subject, that the Data Subject has given his consent to be distributed and to be available to an unlimited circle of persons in accordance with the procedure provided for by the Personal Data Law (hereinafter – personal data authorized for distribution).

2.10. User – any visitor of the https://www.grunwald.ru website.

2.11. Sharing of personal data – actions aimed at disclosing personal data to a specific person or a specific circle of persons.

2.12. Distribution of the personal data – any actions that aim to disclose personal data to an indefinite circle of persons (transfer of personal data) or that may release the personal data to the general public. These actions may include, but are not limited to, publication of personal data in mass media, posting in information and telecommunications networks or providing access to personal data in any other way.

2.13. Cross-border personal data transfer – the transfer of personal data onto the territory of a foreign state to an authority of a foreign state, a foreign individual or a foreign legal entity.

2.14. Personal data destruction – any actions that result in permanent deletion of personal data with inability of further restoration and (or) the destruction of physical personal data storage devices.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right to:

– obtain true and reliable personal data and/or documents containing personal data from the Data Subject;

– resume personal data processing without the consent of the Data Subject on the grounds stated in Personal Data Law in the event the Data Subject withdraws consent to the personal data processing;

– identify the structure and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and other relevant regulatory legal acts independently, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator shall be obliged to:

– provide Data Subject with information concerning the processing of his personal data at his request;

– process personal data in accordance with the procedure established by the current legislation of the Russian Federation;

– respond to requests from Data Subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

– provide necessary information to the bodies authorized with the protection of the Data Subject personal rights within 30 days from the date of receipt of their request;

– publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;

– take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, sharing, and other illegal actions with respect to personal data;

– cease the personal data transfer (distribution, sharing, access), stop processing and erase the personal data under the procedure and in the cases provided for by the Personal Data Law;

– fulfill other duties stipulated by the Personal Data Law.

4. Basic rights and obligations of Data Subjects

4.1. Data Subjects have the right to:

– obtain information concerning the processing of their personal data, except in cases provided for by federal laws. The information provided to Data Subject by the Operator shall be in accessible form, which shall not contain personal data related to other Data Subjects expect in cases where there are legal grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established in the Personal Data Law;

– demand the Operator to confirm the personal data, block or delete or in the event the personal data is incomplete, outdated, inaccurate, obtained illegally or is not relevant for the stated purpose of processing, as well as take measures provided by law to protect their rights;

– impose conditions on preliminary consent while processing personal data in order to promote goods, works and services;

– withdraw consent to personal data processing;

– appeal to the body authorized for Data Subject protection rights, or to appeal in court against illegal actions or inaction of the Operator when processing their personal data;

– exercise other rights provided for by the legislation of the Russian Federation.

4.2. Data Subjects shall be obliged to:

– provide the Operator with reliable data about yourself;

– inform the operator about any change of their personal data.

4.3. Individuals who have provided the Operator with false information about themselves or other Data Subject without consent of the latter are subject to liability in accordance with the legislation of the Russian Federation.

5. The Operator may process the following personal data of the User

5.1. Last name, first name, patronymic.

5.2. Email address.

5.3. Phone numbers.

5.4. Please note that the website also collects and processes anonymous user data (including cookies) via internet statistics services, such as Google Analytics, Yandex Metrica and other.

5.5. All aforementioned data is included in a general term "Personal Data" for the purpose of this Policy.

5.6. The Operator does not process special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, private life.

5.7. Processing of personal data authorized for distribution including special categories of personal data specified in Part 1 of Article 10 of the Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" is allowed in the event the prohibitions and conditions provided for in Article 10.1 of the Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" are observed.

5.8. The User's consent to the processing of personal data permitted for distribution is issued separately from other consents to the processing of his personal data. The conditions stipulated by Article 10.1 of the Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" are observed. The requirements to the contents of such consent are set forward by the bodies authorized with the protection of the Data Subject personal rights.

5.8.1 The User provides their consent to processing of personal data authorized for distribution directly to the Operator.

5.8.2 The Operator is obliged to publish information regarding all processing conditions no later than three working days from the date of receipt of the User's consent.

5.8.3 The Data Subject is eligible to request at any time the transfer (distribution, sharing, access) of his personal data to be terminated. The request must include the full name, contact information (phone number, email address or postal address) of the Data Subject, as well as a list of personal data that is subject to termination. The personal data specified in this request can only be processed by the Operator to whom it was sent.

5.8.4 Consent to the processing of personal data permitted for distribution shall terminate upon receipt by the Operator of the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.

6. Principles of personal data processing

6.1. The Operator processes personal data on a legal and fair basis.

6.2. The personal data is processed in keeping with achieving legal, predetermined, specifically stated purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted.

6.3. It is not allowed to merge databases containing personal data, the processing of which is carried out for purposes incompatible with each other.

6.4. Only personal data that meets the purposes of their processing is subject to processing.

6.5. The contents and the volume of the processed personal data correspond to the stated purposes of processing. Only the data that correspond to the stated purposes of the processing shall be processed.

6.6. When processing personal data, the Operator ensures its accuracy, sufficiency, and compliance to the purposes of personal data processing. The Operator adopts the necessary measures to delete and update the incomplete or inaccurate data.

6.7. Non-anonymized personal data is stored no longer than the purposes of data processing require, unless the storage period is established by federal law or/and a contract to which the Data Subject is a party, beneficiary or guarantor. The processed personal data is destroyed or depersonalized upon reaching the purposes of processing or in case it is no longer necessary to reach said purposes, unless otherwise provided by federal law.

7. Purposes of personal data processing

7.1. Purpose 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 website https://www.grunwald.ru.

7.2. The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The User can always revoke their agreement to receive informational messages from the Operator by sending an email to [email protected] under the subject "Waiver of further notifications about new products, services and special offers".

7.3. Depersonalized User data collected using Internet statistics services are used to collect information about User activity on the website, improve the quality of the website and its content.

8. Legal grounds for processing personal data

8.1. The legal grounds for processing personal data by the Operator are:

– constitutive instruments (articles of association) of the Operator;

– contracts concluded between the Operator and the Data Subject;

– federal laws and other regulatory legal acts in the field of personal data protection;

– User's consent to the processing of their personal data, to the processing of personal data allowed for distribution.

8.2. The Operator processes the User personal data only if they are filled in and/or sent by the User independently through special forms on the website https://www.grunwald.ru or sent to the Operator via e-mail. By filling out the appropriate forms and/or sending their personal data to the Operator, the User agrees with this Policy.

8.3. The Operator processes depersonalized data about the User in the event the User's browser settings allow for it ("cookies" and JavaScript are enabled).

8.4. Data Subject shares his personal data independently and consents voluntarily, freely and in their own interest.

9. Terms of personal data processing

9.1. Personal data may be processed at the consent of the Data Subject to their personal data being processing.

9.2. The personal data is being processed to reach the purposes stipulated by an international agreement of the Russian Federation or a law, and to execute functions, powers and duties assigned to the Operator by the legislation of the Russian Federation.

9.3. The personal data processing is required for administration of justice, the execution of a judicial act, an act of another body or an official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. The processing of personal data is necessary for the execution of a contract to which the Data Subject is a party, beneficiary or guarantor, as well as for the conclusion of a contract on the initiative Data Subject or a contract under which the Data Subject will be the beneficiary or guarantor.

9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant purposes, provided that the rights and freedoms of Data Subject are not violated.

9.6. The personal data that may be available to an unlimited circle of persons by the Data Subject consent or request is subject to processing (hereinafter referred to as publicly available personal data).

9.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.

10. Procedure for the collection, storage, transfer and other types of personal data processing

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 current legislation in the field of personal data protection.

10.1. The Operator ensures the security of personal data and ensures only authorized persons may access it.

10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except for cases related to the implementation of current legislation or if Data Subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract.

10.3. In case the User identifies inaccuracies in their personal data, the User may update it themselves by sending a notification to the Operator's email address [email protected] under the subject "Updating of personal data".

10.4. The term for personal data processing is determined by reaching the purposes for which personal data was collected, unless another term is stipulated by the contract or by the current legislation.

The User can withdraw his consent to the personal data processing at any time by sending a notification to the Operator via e-mail to the Operator's e-mail address [email protected] under subject "Withdrawal of consent to the personal data processing".

10.5. All information collected by third-party services, including payment systems, communication facilities and other service providers, is stored and processed by these actors (Operators) in accordance with their User Agreement and Privacy Policy. Data Subject and / or User shall be obliged to familiarize themselves with these documents in due course. The Operator is nor responsible for the actions of the third parties, including the service providers specified in this paragraph.

10.6. The restrictions set on the personal data transfer (other than granting access), as well as on the processing or processing conditions (other than obtaining access) of personal data permitted for distribution by the Data Subject, do not apply in cases of processing personal data in the state, public and other public interests defined by the legislation of the Russian Federation.

10.7. When processing personal data, the Operator ensures its privacy.

10.8. The Operator stores non-anonymized personal data no longer than the purposes of data processing require, unless the storage period is established by federal law or/and a contract to which the Data Subject is a party, beneficiary or guarantor.

10.9. The cessation of personal data processing may happen in the following cases: in the event of reaching personal data processing purposes, in the event of the expiration of the consent of the Data Subject or the withdrawal of said consent, or in the event of unlawful processing of personal data.

11. List of actions performed by the Operator with the personal data obtained

11.1. The Operator collects, records, systematizes, accumulates, stores, specifies (updates, changes), extracts, uses, transfers (distributes, provides access) depersonalizes, blocks, deletes and destroys personal data.

11.2. The Operator executes personal data automated processing with the receipt and / or transmission of the information received via information and telecommunication networks or without it.

12. Cross-border personal data transfer

12.1. Before commencing cross-border data transfer, the Operator must ensure that the legislation of the foreign state, in whose territory the data is to be stored, provides reliable protection of the Data Subject rights.

12.2. In the event the foreign state does not meet the above requirements for proper cross-border personal data transfer, the transfer may be conducted exclusively with the Data Subject written consent for cross-border personal data transfer or in the event of the contract of which the Data Subject is a party.

13. Personal data privacy

The Operator and other individuals who accessed the personal user data shall not distribute or disclose personal data without the consent of the Data Subject, unless otherwise provided by federal law.

14. Final provisions

14.1. The User may contact the operator at [email protected] email to get more details concerning personal data processing.

14.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.

14.3. The current version of the Policy is freely available on the Internet at https://grunwald.ru/policy/.