PRIVACY POLICY

as of December 27th, 2019

Definitions

Data is defined as any information directly or indirectly related to a specific or identifiable individual (citizen). In particular, such information includes a person’s full name, phone number, and contact email address.

Data Processing refers to any action (operation) or a series/set of actions (operations) performed on Data with or without automation/automation tools. Such activities (processes) include collection, recording, systematization, accumulation, storage, refinement (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deleting, destruction of Data.

Data Safety is defined as Data Protection from unlawful and/or unauthorized access to, destruction, change, blocking, copying, provision, distribution, and any other illegal actions regarding Data.

The purpose of creating this website by LLC “ESI INNOLAND” (Address: 119530 Moscow Ochakovskoe highway, H.28 Bld.2, 1st Floor, Room 1, INN / KPP: 9729289186/772901001, PSRN (Primary State Registration Number): 1197746576906) (Company) is to provide individuals and legal entities (users) with the necessary information about Company’s activities and to inform them about goods and services (products) that LLC “ESI INNOLAND” produces/provides. The content of this website is, for the most part, informative.

This website’s content is owned by LLC “ESI INNOLAND” and is protected by the current copyright legislation. Therefore, website users can use its content for personal and non-commercial purposes. Using the website’s content for other purposes is strictly prohibited.

The Company prohibits changing the website’s content in any way and subsequent reproduction/recreation of it.

Please note that the Company’s website may contain links and forms leading to other websites. In this case, the Company is not responsible for the privacy of the information on other websites.

The Company reserves the right to change Privacy Policy to improve further Data Protection System, which protects Your Personal Data from unauthorized access.

Every time You provide Your personal information to the Company’s stores, send it via email, fill out forms on the website, or report Your personal information in person, the Company collects Your personal information (Personal Data). By providing the Company with Your Personal Data, You agree to the terms and conditions specified in this section. You have the right to change, update or request to delete Your Data in accordance with the current legislation and LLC “ESI INNOLAND” company Personal Data Protection policy.

Upon filling out forms on this website or documents, including those in the Company stores, You can provide the following information:

• Name;
• Contact phone number and email address via which We may reach You.

The Company also collects certain statistical information. For example:

• User’s IP address;
• Type of browser;
• Date, time, and number of visits;
• Website’s address from which the user clicked through to the Company’s site.
• Location information;
• Information about web pages visited and/or about ad-banners viewed;
• Information provided by Your browser (device type, browser type, version, operating system, etc.).

We guarantee the following

LLC “ESI INNOLAND” treats the issue of privacy of their users very seriously and respects the privacy rights of every website user.

The Company guarantees that NO information received from You will ever, under any circumstances, be provided to third parties without Your consent, excluding cases specified in the Russian Federation’s current legislation.

The Company guarantees that the Personal Data You provided to the Company will be processed in strict compliance with the current legislation. Data is stored at the Russian Federation servers and is protected in accordance with the current legislation.

The Company does not process Biometric Data (information describing person’s physiological and biological characteristics using which one can determine person’s identity and which are used by the operator to identify the person).

The Company is entitled to transfer Data to third parties in cases specified in the Russian Federation legislation.

Based on the agreement concluded between the Company and Data subjects and given the data subject’s consent, the Company has a right to assign Data Processing to third parties.

Parties engaged in Data Processing under an agreement concluded with the Company (operator’s assignment) undertake to comply with the Data Processing and Protection rules and principles in accordance with the Law.

For any third party, the agreement specifies a set of actions (operations) performed on Data, which will be executed by the third party engaged in Data Processing and the goals of said processing. This type of agreement establishes the responsibility of each third party to maintain privacy and confidentiality and ensure Data Security during its processing and Processed Data Protection requirements, which comply with the Law.

To comply with the current legislation of the Russian Federation and their contractual obligations, the Company processes Data with and without the use of automation/automation tools. The complete sequence/set of processing operations includes collection, recording, systematization, accumulation, storage, refinement (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deleting, destruction of Data.

The decision-making process based solely on automated Data Processing and resulting in legal consequences for the data subject or in any other way affecting their rights and legitimate interests is strictly prohibited, excluding cases specified in the Russian Federation legislation.

Data Protection requirements

Upon Data Processing, the Company takes necessary legal, organizational, and technical measures to protect the Data from unlawful and/or unauthorized access to, destruction, change, blocking, copying, provision, distribution of, and any other illegal actions.

According to the Law, such measures mainly include:

• appointment of the person responsible for the organization of Data Processing and the person responsible for ensuring Data Security;
• development and approval of local acts regarding Data Processing and Protection;
• enforcement of legal, organizational, and technical measures ensuring Data Security;
• overseeing the actions taken to ensure Data Security and the security level of Personal Data information systems;
• detection of Data Security threats during Data Processing via Personal Data information systems;
• enforcement of organizational and technical measures ensuring Data Security during Data Processing via Personal Data information systems necessary to comply with the Data Protection requirements, compliance with which ensures maintaining the Data security levels established by the government of the Russian Federation;
• application of Data Protection instruments which successfully passed conformity assessment procedure in accordance with the established practice;
• evaluation of the effectiveness of measures taken to ensure Data Security before implementing Personal Data information system
• keeping records of machine Data carriers if Data is stored via machine carriers;
• detection of unauthorized access to Data and taking measures to prevent such occurrences from happening in the future;
• recovery of Data modified or destroyed as a result of unauthorized access;
• establishment of Data Access rules for Data Processing via Personal Data information system and ensure registration and keeping records of all actions performed on Data in Personal Data information system.
• evaluation of potential harm to the Data subjects in case of breach of Law requirements and the ratio of said harm to measures taken by the Company in pursuit of ensuring the fulfillment of obligations specified in the Law;
• compliance with conditions eliminating unauthorized access to Data material carriers and ensuring Data Security;
• familiarisation of Company employees directly involved in Data Processing with the provisions of Data Law of the Russian Federation and local acts regarding Data Processing and Protection and relevant Company employee training.

Data Processing (Retention) Periods

Data Processing (Retention) Periods are defined based on the goals of Data Processing in accordance with the term of the agreement between the Company and Data subject as well as with the federal law requirements and Data operators’ requirements on assignment from which the Company executes Data Processing, also in accordance with the main working rules of organizations’ archives and with the statute of limitations. If Data Processing (Retention) Period expired, said Data must be destroyed unless the federal law specifies otherwise. Upon cessation of Data Processing, Data Storage is allowed only after Data depersonalization.

Changes and Updates

The Company reserves the right to make necessary changes to the website, replace or delete any part of its content, and limit website access at any time at the Company’s discretion. The Company also reserves the right to change Privacy Policy to improve further Data Protection System, which protects Your Personal Data from unauthorized access.