User Agreement and Personal Data Processing Policy

 

Version No. 1
Date: October 29, 2021

  1. General definitions
  1. Atlima’s websites shall mean a set of graphic and informational materials and programs and databases that make them available on the Internet at the network address https://atlima.ru, as well as websites hosted in the atlima.ru domain and its subdomains, as well as Atlima’s mobile applications.
  2. Automated processing of personal data shall mean processing of personal data with the use of computer technology.
  3. Blocking of personal data shall mean temporary suspension of the processing of personal data (except when it is needed to clarify personal data).
  4.  Information system of personal data shall mean a set of personal data included in databases and information technologies and technical means that ensure their processing.
  5. Depersonalization of personal data shall mean actions as a result of which it is impossible to determine, without the use of additional information, which personal data belongs to which  specific User or other subject of personal data;
  6. Processing of personal data shall mean 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 (updates, changes), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deleting, destruction of personal data.
  7. Operator shall mean a legal entity that organizes and (or) carries out independently or jointly with other persons the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data. The operator shall be Atlima LLC (INN: 9723125738).
  8. Personal data shall be any information related directly or indirectly to a specific or identifiable User of Atlima’s websites.
  9. Personal data permitted by the subject of personal data for distribution shall mean personal data with access to an unlimited number of persons provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (“the Personal data permitted for distribution”).
  10. User shall be any visitor to Atlima’s websites, a capable individual who joined this Agreement in their own interest or acts on behalf and in the interests of the legal entity they represent.
  11. Provision of personal data shall be actions aimed at disclosure of personal data to a certain person or a certain circle of persons;
  12. Dissemination of personal data shall be any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including the publication of personal data in the mass media, posting personal information in information and telecommunications networks, or providing access to personal data in any other way;
  13. Cross-border transfer of personal data shall be transfer of personal data to the territory of a foreign state to the authority of a foreign state, foreign individual or foreign legal entity;
  14. Destruction of personal data shall be any actions as a result of which personal data is irrevocably destroyed without possibility of further restoration of the content of personal data in the personal data information system, and (or) the physical carriers of personal data are destroyed
  15. When new versions of the Policy regarding the processing of personal data are published, the User will be notified accordingly when entering the websites. All versions will be available via links posted on the websites.
  1.  General provisions
  1. Your use of Atlima’s websites in any way and in any form within its declared functionality, including:
  1. viewing materials posted on websites;
  2. registration and/or authorization on websites;
  3. placement or display on the websites of any materials, including but not limited to such as texts, hypertext links, images, audio and video files, data and/or other information;

forms the agreement based on the terms of this Agreement in accordance with the provisions of Articles 437 and 438 of the Civil Code of the Russian Federation..

  1. By using any of the above options for using the websites, you confirm that:
  1. Read the terms of this Agreement in full before using the websites;
  2. Accept all the terms of this Agreement in full without any exceptions and restrictions on your part and undertake to comply with them or cease using the websites. If you do not agree with the terms of this Agreement or do not have the right to conclude an agreement on their basis, you should immediately cease any use of the websites;
  3. The Agreement (including any of its parts) may be changed by the Operator without any special notice. The new version of the Agreement shall come into force from the moment it is posted on the websites by the Operator or brought to the attention of the User in another convenient form, unless otherwise provided by the new version of the Agreement.
  1. General conditions for using the websites
  1. The use of the functionality of the websites is permitted only after the User has completed registration and authorization on the websites in accordance with the established procedure.
  2. Technical, organizational and commercial conditions for the use of websites, including their functionality, are brought to the attention of the Users by separate postings on the websites or by notifying the Users.
  3. The login and password selected by the User are necessary and sufficient information for the User to access the websites. The User does not have the right to transfer their login and password to third parties, bears full responsibility for their safety and independently chooses the method of their storage.

 

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  1. General provisions of the personal data processing policy
  1. This personal data processing policy is drawn up in accordance with the requirements of Federal Law No. 152-FZ On Personal Data as of July 27, 2006 (“the Law on Personal Data”) and determines the procedure for processing personal data and measures to ensure the safety of personal data taken by Atlima LLC, INN: 9723125738 (“the Operator”).
  2. The Operator sets as the 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 their personal data, including the protection of the rights to privacy, personal and family secrets.
  3. This Operator’s personal data processing policy (“the Policy”) applies to all information that the Operator can obtain about the visitors to https://atlima.ru 
  1. Main rights and obligations of the Operator
  1. The Operator is entitled to:
– obtain from the subject of personal data reliable information and/or documents containing personal data;
– in the event that the subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data;
– independently determine the composition and list of measures that are necessary and sufficient to ensure the fulfillment of the obligations prescribed by the Law on Personal Data and the regulatory legal acts adopted in accordance therewith, unless otherwise provided by the Law on Personal Data or other federal laws;
– transfer personal data
  1. The Operator is obliged to:
– at the request of the subject of personal data, provide the subject of personal data with the information regarding the processing of their personal data;
– give responses to requests and inquiries from the subjects of personal data and their legal representatives in accordance with the requirements of the Law on Personal Data;
– at the request of the authorized body responsible for protecting the rights of the subjects of personal data, provide the authorized body with the necessary information within 30 days from the date of receipt of such a request;
– publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
– take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
– cease transfering (distributing, providing, granting access) of personal data, cease processing and destroy personal data in the manner and in the events provided for by the Law on Personal Data;
– perform other duties prescribed by the Law on Personal Data.
  1. Basic rights and obligations of the subjects of personal data
  1. The subjects of personal data are entitled to:
– obtain information regarding the processing of their personal data, except as otherwise provided by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
– require the Operator to clarify their personal data, block or destroy such data if the personal data is incomplete, outdated, inaccurate, illegally obtained or not needed for the stated purpose of processing, as well as take legal measures to protect their rights;
– set forth the condition of prior consent when processing personal data in order to promote goods, works and services in the market;
– withdraw the consent to the processing of personal data;
– appeal to the authorized body responsible for protecting the rights of subjects of personal data or to the 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.
  1. The Subjects of personal data are obliged to:
– provide the Operator with reliable personal data;
– inform the Operator on the clarification (updates, changes) of their personal data
  1. Persons who provided the Operator with false personal information or information on another subject of personal data without the consent of the latter shall be liable in accordance with the legislation of the Russian Federation.
  1. The Operator may process the following personal data of the User
  1. Surname, name, patronymic.
  2. Email address.
  3. Phone numbers.
  4. Year, month, date and place of birth.
  5. Photos.
  6. Information on education, profession, field of studies and qualification, details of education certificates.
  7. The websites also collect and process anonymous data on visitors (including «cookie» files) using Internet statistics services (Yandex Metrika and Google Analytics and others).
  8. The above data (“the Policy”) share the general concept of Personal data.
  9. The Operator does not process special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life.
  10. Processing of personal data permitted for distribution from the special categories of personal data specified in Part 1 of Article 10 of the Law on Personal Data is permitted in case of compliance with the prohibitions and conditions provided for in Article 10.1 of the Law on Personal Data.
  11. The User’s consent to the processing of personal data permitted for distribution shall be issued separately from other consents to the processing of their personal data.
  1. The User shall provide the Consent to the processing of personal data permitted for distribution directly to the Operator.
  2. No later than three working days from the date of receipt of the specified consent of the User, the Operator is obliged to publish information on the terms of processing, on the existence of prohibitions and terms for the processing of personal data permitted for distribution by an unlimited number of persons.
  3. The transfer (distribution, provision, access) of personal data authorized by the subject of personal data for distribution must be terminated at any time at the request of the subject of personal data. This requirement should include the surname, first name, patronymic (if any), contact information (telephone number, email address or postal address) of the subject of personal data, as well as the list of personal data the processing of which is subject to termination. The personal data specified in this request can be processed only by the Operator to which it is sent. The consent to the processing of personal data permitted for distribution shall terminate from the moment the Operator receives the request specified in this paragraph regarding the processing of personal data.
  1. Principles of processing personal data
  1. The processing of personal data is carried out on a legal and fair basis.
  2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. It is not allowed to process personal data that is incompatible with the purposes of collecting personal data.
  3. It is not allowed to combine databases containing personal data the processing of which is carried out for purposes that are incompatible with each other.
  4. Only personal data that meet the purposes of their processing are subject to processing.
  5. The content and scope of the processed personal data correspond to the stated purposes of processing. The excessiveness of the processed personal data in relation to the stated purposes of their processing is not allowed.
  6. When processing personal data, the Operator shall ensure accuracy of personal data, as well as their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data. The Operator shall take the necessary measures and/or ensure their adoption to remove or clarify incomplete or inaccurate data.
  7. Storage of personal data is carried out in a form that allows the Operator to determine the subject of personal data no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by federal law, an agreement the party, beneficiary or guarantor of which is the subject of personal data. The processed personal data is destroyed or depersonalized upon achieving the goals of processing or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.
  1. Purposes of processing personal data
  1. The purposes of processing the User’s personal data are as follows:
– informing the User by sending emails;
– entering into, executing and terminating civil law contracts;
– advertising purposes;
– providing the User with access to the services, information and/or materials contained on the websites.
  1. The Operator also has the right to send notifications to the User on new products and services, special offers and various events. The User can always refuse to receive newsletters by sending a message to the Operator’s email stanislavsyrygin@atlima.ru marked as “Refusal of notifications on new products, services and special offers”.
  2. The Users’ depersonalized data collected using Internet statistics services are used to collect information on the actions of the Users on websites, improve the quality of the websites and their content.
  1. Legal grounds for processing personal data
  1. The legal grounds for the processing of personal data by the Operator are as follows:
– agreements concluded between the Operator and the subject of personal data;
– federal laws, other regulatory legal acts in the field of personal data protection;
– the Users’ consent to the processing of their personal data permitted for distribution
  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 websites or sent to the Operator by email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
  2. The Operator processes depersonalized data about the User if it is allowed in the User’s browser settings (saving cookies and JavaScript technology are enabled).
  3. The subject of personal data independently makes a decision on the provision of their personal data and gives consent with their own will and volition, as well as in their own interest.
  4. The subject of personal data also expresses their consent to receive advertising materials in accordance with the Federal Law On Advertising No. 38-FZ as of March 13, 2006, including from third parties — partners of the Operator.
  1. Terms of processing personal data
  1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
  2. The processing of personal data is necessary to achieve the goals provided for by an international treaty of the Russian Federation or the law, to carry out the functions, powers and duties assigned by the legislation of the Russian Federation to the Operator.
  3. The processing of personal data is necessary for the delivery of justice, execution of a judicial act, act of another body or official subject to execution in accordance with the RF legislation on enforcement proceedings.
  4. The processing of personal data is necessary for the execution of an agreement the party, beneficiary or guarantor of which is the subject of personal data, as well as for entering into an agreement on the initiative of the subject of personal data or an agreement under which the beneficiary or guarantor will be the subject of personal data.
  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 goals, provided that the rights and freedoms of the subject of personal data are not violated.
  6. The Operator processes personal data with access of an unlimited number of persons provided by the subject of personal data or at request of the latter (“the publicly available personal data”).
  7. The Operator processes personal data subject to publication or mandatory disclosure in accordance with federal law.
  1. Procedure for collecting, storing, transferring and otherwise processing personal data
  1. The safety 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.
  2. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.
  3. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of applicable law or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
  4. In case of detection of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator’s email stanislavsyrygin@atlima.ru marked as “Updating personal data”.
  5. The time period for the processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided by the agreement or applicable law.
  6. The User may at any time withdraw their consent to the processing of personal data by sending a notification to the Operator to the Operator’s email stanislavsyrygin@atlima.ru marked “Withdrawal of consent to the processing of personal data”.
  7. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to independently get acquainted with the specified documents in a timely manner. The Operator shall not be responsible for any actions of third parties, including the service providers specified in this clause.
  8. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or processing terms (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests determined by the legislation of the Russian Federation.
  9. When processing personal data, the Operator ensures the confidentiality of personal data.
  10. The Operator shall store personal data in a form that allows the Operator to determine the subject of personal data no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by federal law, an agreement the party, beneficiary or guarantor of which is the subject of personal data.
  11. The processing of personal data may be terminated upon the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data or the withdrawal of consent by the subject of personal data, as well as the identification of unlawful processing of personal data.
  1. List of actions performed by the Operator with the obtained personal data
  1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides accesses), depersonalizes, blocks, deletes and destroys personal data.
  2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks or without such information.
  1. Cross-border transfer of personal data
  1. Before the start of the cross-border transfer of personal data, the Operator is obliged to make sure that the foreign state to the territory of which personal data will be transferred provides reliable protection of the rights of subjects of personal data.
  2. Cross-border transfer of personal data in the territory of foreign states that do not meet the above requirements can be carried out only if there is a written consent of the subject of personal data to the cross-border transfer of their personal data and/or execution of an agreement the party of which is the subject of personal data.
  3. The subject of personal data expresses their consent to the cross-border transfer of personal data.
  1. Confidentiality of personal data
  1. The Operator and other persons who obtained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
  1. Final provisions
  1. The User can receive any clarifications on any issues regarding the processing of their personal data by contacting the Operator via email stanislavsyrygin@atlima.ru.
  2. This document will reflect any changes in the personal data processing policy made by the Operator. The policy is valid for an indefinite time period until it is replaced by a new version.
  3. The current version of the Policy is freely accessible on the Internet at https://atlima.ru/.