Personal Data Processing Policy

 (edited on November the 15th, 2018)

This Policy is a document defining the policy of the limited liability company "AI VAO", Primary State Registration Number 1147847415187, Tax ID 7801644225 (hereinafter – the company) in regard to the processing of personal data the company may obtain from the subjects of personal data, which in one way or another use the website in the Internet at the address: https://vsh25.net (hereinafter – the Site) and / or any services available through the Site(hereinafter-the Service (s)). Further, the relevant personal data subjects are collectively referred to as "users" and individually as "user".

The use of the Site (in particular, any of its pages) and / or the use of any Services means the unconditional agreement of the user with this Policy and the conditions for the processing of his personal data specified therein; in case of disagreement with these terms and conditions, the user must refrain from using the Site and / or the Services.

1. GENERAL PROVISIONS

1.1. Within the framework of this Policy, the user's personal data means:

1.1.1. Personal data (name, surname, patronymic, phone number, e-mail address, etc.), which the user provides about himself / herself during the registration procedure on the Website, as a result of which a unique account (personal account) is created for the user, or in any other way;

1.1.2. Data that is automatically transmitted by the user's device through which he / she accesses the Site and / or Services, including IP address, cookie data, information about the user's browser (or similar program), technical characteristics of the equipment and software used by the user, date and time of access to the Site and / or Services, addresses of the requested pages and other similar information.

1.2. This Policy applies exclusively to the Site and Services available through the Site. The company does not control and is not responsible for the websites of third parties to which the user can click on the links available on the Website.

2. PURPOSE OF PROCESSING PERSONAL DATA OF USERS

2.1. The Company processes users' personal data only for the following purposes:

  • provision of services by the Company to users in accordance with the agreement concluded with users (user agreement), in particular, ensuring the availability of Services for users (including by sending information digests (news collections), analytical materials to users ' e-mail addresses);
  • creation of unique user accounts (personal accounts) on the Site;
  • providing users with reference and marketing information, including marketing information of third parties - partners of the Company;
  • providing users with the opportunity to contact the Company, including in order to support users; 
  • providing users with advice on issues related to the services provided by the Company.

3. CONDITIONS OF PROCESSING THE PERSONAL DATA OF USERS

AND ITS TRANSFER TO THIRD PARTIES

3.1. The legal basis for the processing of users ' personal data by the Company is an agreement concluded between the users and the Company (the user agreement, the current version of which is always available on the Website at the following address: https://vsh25.net/user-agreement) and / or the user's consent to the processing of his / her personal data by the Company. If there is no agreement between the Company and the user, when sending any information to the Company, including when filling out the feedback form posted on the Website, the user gives the Company consent to the processing of all personal data provided by the user.

3.2. The Company processes only those personal data of users, the content and volume of which corresponds to the processing purposes specified in section 2 of this Policy. To achieve the objectives specified in section 2 of this Policy, the Company processes the following personal data of the user: name, surname, patronymic, telephone number, e-mail address, and other data that the user independently wished to inform the Company, as well as due to the technical features of the Internet operation, the data specified in paragraph 1.1.2. this policy.

3.3. In some cases, in particular, in order to return the funds paid by the user upon occurrence of the circumstances specified in the user agreement, the Company may process the user's personal data, which are additionally provided (sent) by the user. The provision (direction) of the relevant personal data by the user to the Company means the user's consent to the processing of the specified personal data by the Company.

3.4. During the processing of personal data, the Company has the right to carry out: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction of personal data of users.

3.5. As a General rule, the processing of personal data of users is carried out using automation tools. In exceptional cases, the processing of personal data of users can be carried out without the use of these means, subject to mandatory compliance with all requirements stipulated by applicable law.

3.6. The processing of personal data of users is carried out during the period necessary to achieve the objectives specified in section 2 of this Policy and / or during the period stipulated by the agreement (user agreement) with users and / or during the period stipulated by the current legislation.

3.7. With regard to personal data of users, their confidentiality is maintained, except in cases of voluntary provision of information about themselves for public access to an unlimited number of persons.

3.8. The user hereby fully agrees with the possibility of cross-border transfer by the Company of any of his personal data to third parties located on the territory of foreign States that are parties to the Council of Europe Convention on the protection of individuals in the automated processing of personal data, as well as other foreign States that provide adequate protection of the rights of personal data subjects outside the Russian Federation (the names of such third parties will be communicated by the company to the User additionally by sending a message to the user's e-mail address specified by him when creating a personal account on the Website).

The transfer of personal data of users in accordance with this paragraph is carried out for the purpose of providing relevant marketing information to users by third parties that are partners of the Company, i.e. information about the goods, services, works, property rights offered by these third parties, etc. the Relevant third parties have the right to process personal data of users in compliance with the requirements established by the legislation of incorporation for the protection of processed personal data in such ways as: systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, destruction of personal data of the user.

3.9. By achieving the goals / after the period for processing personal data / when the user withdraws his consent to the processing of personal data, the user's personal data are subject to irrevocable destruction.

3.10. The Company takes the necessary organizational and technical measures to protect users' personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as other illegal actions of third parties. When processing personal data of users by employees of the Company, the processing of the relevant data is carried out only by authorized employees of the Company, who have undertaken to maintain the confidentiality of such data and who have been acquainted with the provisions of the legislation of the Russian Federation on personal data, including the requirements for the protection of personal data, as well as with the local acts of the Company on the processing of personal data. Processing of personal data of users is carried out by the Company using databases located on the territory of the Russian Federation.

4. THE RIGHTS AND OBLIGATIONS OF THE WEBSITE USER

4.1. Users have the right:

4.1.1. To require clarification of their personal data, its updating, blocking or destruction;

4.1.2. To receive a list of their personal data processed by the Company, the source of their receiving, information about the terms of processing of their personal data, including the terms of its storage, and other information about the processing of their personal data, provided by applicable law;

4.1.3. To require all persons who have previously been informed of any incorrect or incomplete personal information to be notified of any corrections or additions; 

4.1.4. To appeal in the prescribed manner unlawful actions or omissions in the processing of their personal data.

4.2. Users agree to provide only reliable information about themselves.

4.3.If the Company processes personal data on the basis of consent to the processing of personal data, such consent shall be issued by the user for the entire period necessary for the Company to achieve the processing purposes specified in section 2 of this Policy.

5. LIABILITIES OF THE COMPANY

5.1. The company undertakes:

5.1.1. To use the personal data obtained solely for the purposes specified in section 2 of this Policy;

5.1.2. To ensure the storage of data in secret, not to disclose them without the prior written permission of the user, and not to sell, exchange, publish or disclose in other possible ways the user's personal data, except as provided for in this Policy and applicable law;

5.1.3. To take measures stipulated by the legislation and local acts of the Company to protect the confidentiality of personal data of users;

5.1.4. To block personal data related to the respective user from the moment of receiving of the user's request or his / her legal representative or the authorized body for the protection of the rights of personal data subjects for the period of verification in case of identification of inaccurate personal data or illegal actions;

5.1.5. To provide the user, upon receipt of a request from him or his legal representative that meets the requirements of the legislation, with a list of personal data processed by the Company for such use, the source of their receipt, information on the terms of processing of personal data, including the terms of their storage, and other information on the processing of his;

5.1.6. To clarify the user's personal data, update, block, destroy them, as well as to eliminate any violations of the legislation made in the processing of personal data in the manner prescribed by applicable law.

6. ADDITIONAL CONDITIONS

6.1. Any requests / appeals of users / legal representatives of users / authorized state bodies on the issues of processing of personal data by the Company, including those related to inaccuracy of processed personal data, illegality of their processing, revocation of consent, as well as user's access to their data shall be sent in writing (by registered and / or valuable letter, Express mail) to the address of the Company: Russia, 199178, St. Petersburg, 18th line V. O., b. 29, lit. A, r. 1N, cab. 166 or by sending an appropriate request / request to the following e-mail address of the Company: info@vsh25.net. The request / appeal must contain at least: surname, name, patronymic of the user, e-mail address, and other data in cases provided by the current legislation.

6.2. The company has the right to make changes to this Policy without the user's consent.

6.3. The new version of the Policy comes into force from the moment of its posting on the Website, unless otherwise is provided by the new version of the Policy.

6.4. The current version of this Policy is always publicly available on the Website at: https://vsh25.net/private-policy.

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