Privacy policy and user agreement

PRIVACY POLICY AND USER AGREEMENT WITH
SIVER LLC

Petrozavodsk

Address: Kuybysheva Str. 10

Telephones: (8142) 59-40-78, +7-911-414-44-01

1. General

1.1. The policy of personal data processing (hereinafter referred to as Policy) aims at protecting the rights and freedoms of individuals, whose personal data are processed by Siver Limited Liability Company (hereinafter referred to as Data Operator).

1.2. The policy was developed in compliance with paragraph 2 Part 1 Art. 18.1 of Federal Law of July 27, 2006, N 152-FZ “On personal data” (hereinafter referred to as the Federal Law “On personal data”).

1.3. The policy contains information subject to disclosure under part 1 Art. 14 of the Federal Law “On personal data” and is a public document.

2. Data Operator's details

2.1. The Data Operator's principal place of business is Kuybysheva Str. 10, Petrozavodsk, Republic of Karelia, 185003.

3. Personal data processing

3.1. The Data Operator shall process personal data in a lawful and fair manner in order to perform functions, exercise legal powers and duties, rights and lawful interests of the Data Operator, its employees and third parties.

3.2. The Data Operator obtains personal data directly from personal data owners.

3.3. The Data Operator shall process personal data using automated and non-automated methods, with and without any PCs.

3.4. Personal data processing includes collection, recording, classification, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction.

4. Personal customer data processing

4.1. The Data Operator shall process personal customer data as part of its legal arrangements governed in part 2 of the Civil Code of the Russian Federation of January 26, 1996, N 14-FZ.

4.2. The Data Operator shall process personal customer data in order to comply with the laws of the Russian Federation, as well as to:

  • process applications and requests from personal data owners;
  • inform about new products, special promos and offers;
  • conclude and execute the contract.

4.3. The Data Operator shall process personal customer data with the approval provided by customers and/or their legal representatives through concluding actions on this website, including, but not limited to, placing an order, signing up, subscribing to newsletters in compliance with this Policy.

4.4. The Data Operator shall process personal customer data for no longer than needed for the purpose of such personal data processing, unless otherwise specified in the laws of the Russian Federation.

4.5. The Data Operator may process the following personal customer data:

  • Full name;
  • DOB;
  • Address;
  • Contact telephone;
  • Email.

4.6. Yet, some categories of personal data are not subject to processing:

  • race, nationality;
  • political views, religious or philosophical beliefs;
  • health and sexual life details.

5. Personal data security

5.1. When processing personal data, the Data Operator shall take necessary legal, organizational and technical measures or ensure the same to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, disclosure, distribution, as well as from other unlawful actions.

5.2. The personal data security measures during processing by the Data Operator shall be planned and put in place to ensure compliance with Art. 19 of Federal Law FZ-152 “On personal data”.

5.3. Subject to Art. 18.1 of Federal Law FZ-152, the Data Operator shall independently determine the scope and list of measures necessary and sufficient to ensure legal compliance. In particular, the Data Operator has taken the following measures:

  • appointed an officer responsible for personal data processing;
  • developed and put in place in-house acts on personal data processing, as well as in-house procedures aimed at preventing, identifying any breach of established procedures of personal data processing and eliminating the consequences of such breach;
  • legal, organizational and technical measures to ensure personal data security under Art. 19 of Federal Law FZ-152;
  • put in place in-house control of compliance of personal data processing with FZ-152 and relevant acts and requirements for personal data security, its policy of personal data processing, in-house acts;
  • assesses any potential harm to personal data owners in case of breach of Federal Law FZ-152, the proportion of harm to the protective measures taken by the Data Operator in compliance with FZ-152;
  • the employees of the Data Operator directly involved in personal data processing are familiar with the laws of the Russian Federation governing personal data, including personal data security, documents included in the scope of the Data Operator's policy of personal data processing, in-house acts on personal data processing;
  • in addition to Federal Law 152-FZ "On personal data", the Data Operator shall take measures to protect customer, employee and contractor information.

6. Rights of personal data owners

6.1. Personal data owners shall be entitled to:

  • obtain their personal data and information relating to their processing;
  • clarify, block or destroy their personal data if they are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing;
  • revoke the consent given to the processing of personal data;
  • have their rights and legal interests secured, seek compensation of losses and moral damage in court;
  • appeal against the actions or omissions of the Data Operator, having addressed the authorized body advocating the rights of personal data owners or the court.

6.2. To exercise their rights and legal interests, personal data owners may contact the Data Operator or send a request personally or through a representative. The request must contain the information specified in part 3 Art. 14 of the Federal Law “On personal data”.