1. General Terms
1.1. This Policy is the official document of CJSC “The Arctic Circle Company” (OGRN (primary state registration number) 1031000750010) (hereinafter - the Website administration) and defines the procedure for processing and protection of information on users of the website https://www.pkrug.ru/ (hereinafter - the Website), services and software products of the Website (hereinafter - Users) which Users of the Website can obtain while using the Website or after authorization on the Website.
1.3. The Website administration has the right to change this Policy in its sole discretion. The Website administration notifies the Users about making changes to the Policy by posting the new version of the Policy on the Website () not later than one day before the entry into force of the corresponding amendments.
1.4. This Policy applies to all the processes of collection, record, systematization, accumulation, storage, specification (update, change), extract, usage, transfer (provision, access), blocking, destruction of personal data, with the help or without the automation equipment.
1.5. Using the Services and providing information, which is needed to initiate further interaction, to the Website administration the User expresses his consent to its use according to this Policy (including, but not limited to, the possibility of transferring personal data to the third parties by the Website administration entrusted with the processing of personal data, including, but not limited to, transfer (if necessary) and subsequent processing of personal data to the persons belonging to the same group as CJSC “The Arctic Circle Company” and/or third parties engaged to process personal data and approved for the processing of personal data. In case of disagreement with these conditions the User must refrain from using services.
2.1. Providing services to Users of the Website and its services (hereinafter - the Website services), the Website administration, acting reasonably and conscientiously, believes that the User:
- Has all the necessary rights allowing him to register and use the Website;
- Provides reliable information about himself to the extent required to use the Website;
- Is acquainted with this Policy, agrees with them and assumes the rights and duties specified in them.
2.2. The Website administrator does not verify the reliability of the obtained (collected) information about Users, except for the cases when such verification is necessary to execute the obligations of the Website administration towards the User.
2.3. If the User accesses an account with a registered login and password then the access is considered as valid by default and the person providing the access is considered to have all the necessary powers except for the cases when the User filed the report of his account being hacked.
3. Purposes of Information Processing
The Website administration processes information about Users, including their personal data, in order to fulfill the obligations of the Website administration to the Users regarding the use of the Website and providing the User with access to services, information and/or materials contained on the Website to process incoming requests from individuals, to provide advice on various issues related to the Company’s entrepreneurship, to conclude contractual relations; for the Company’s entrepreneurship as a Website owner; to analyze the actions of an individual on the Website and functioning of the Website.
4. User Profile
4.1. Personal data of Users. Personal data of Users includes:
4.1.1. Provided by Users and minimum required for registration on the Website: name, mobile phone number, email;
4.1.2. Data additionally provided by Users using the Website tools (location information, OS type and version, Browser type and version, device type and its screen resolution; the source where the User came from; from what website or following what advertisement; OS and Browser language; which pages the User opens and which buttons the user presses; IP address); data about the User which will become known during the contracts execution in cases of conclusion of these contracts, and other public information about the User.
4.1.3. Data additionally provided by Users at the request of the Website administration to fulfill its civil contract obligations to the Users. The Website administration has the right to request additional information from the User which, at the discretion of the Website administration, will be necessary and sufficient to identify the User and will prevent abuse and violation of the third parties’ rights.
4.2. Other information about Users processed by the Website administration.
Other information about Users may include technical means (devices) data, technological interaction with the Website, cookies, other information generated by Users on the Website outside the page editing section, as well as information obtained as a result of the User’s actions on the Website and actions of the other users on the Website.
5. Processing Data about Users
5.1. Processing personal data is based on the principles of:
a) Legitimacy of the purposes and means of personal data processing;
c) Compliance of the personal data processing purpose with the goals predetermined and stated during collection of personal data as well as the authority of the Website administration;
d) Compliance of the scope and nature of the processed personal data, ways of personal data processing with the goals of personal data processing;
e) Inadmissibility of integration databases created for incompatible purposes, contained personal data.
5.2. Personal data of the User is collected on the Website at the time of registration, filling feedback forms, as well as further information provided by the user on his own initiative using Website tools.
5.3. Providing personal data of the User at the request of state bodies (local authorities) is carried out in the manner prescribed by the legislation.
5.4. The Website services can provide access to payment services if necessary, while the Website administration doesn't receive or store payment data of Users’ bank cards.
5.5. While collecting personal data the Website administration undertakes to provide collection, systematization, accumulation, storage, specification (update, change), personal data extraction of Russian Federation citizens using databases located on the Russian Federation territory.
6. Rights and Obligations of Users.
6.1. Users have the right to:
6.1.1. Access their information without restrictions and free of charge about themselves by uploading their personal pages on the Website using login and password;
6.1.2. Independently make changes and corrections to information about themselves on the Users’ personal page on the Website, provided that such changes and corrections contain relevant and reliable information;
6.1.3. Based on a request receive information from the Website administration regarding the processing of their personal data;
6.1.4. Demand from the Website administration to stop processing their personal data including revocation of consent to the processing of personal data, except for cases provided for by the Russian Federation legislation.
6.2. The Website administration is not responsible for the disclosure of the User’s personal data by other Website Users or other persons who have received access to such data as a result of the User’s actions.
7. Measures to Protect Users Information
7.1. The Website administration takes technical, organizational and legal measures to protect User’s personal data from unauthorized or accidental access, destruction, change, blocking, copying, dissemination as well as from other illegal actions.
7.2. Login and password are used to authorize access to the Website. The User is responsible for the safety of this information. The User does not have the right to transfer his own login and password to third parties and is also obligated to take measures to ensure their confidentiality.
8. Final Terms
8.1. This Policy is mandatory for familiarization and implementation by the CJSC “The Arctic Circle Company” employees involved in personal data processing as well as persons included in the same group of companies with CJSC “The Arctic Circle Company” and/or third parties involved in personal data processing and admitted to personal data processing.
8.2. The Website administration does not make decisions that entail legal consequences for users or affect their rights and legitimate interests in other ways, based solely on automated personal data processing.
8.3. If the Website administration entrusts personal data processing to another person, then the Website administration is responsible to the subject of personal data for the actions of the specified person. Data processor on behalf of the Website administration is responsible to the Website administration.
8.4. Users are notified that the Website administration carries out cross-border transfer of Users’ personal data.
8.5. The Website administration has the right to transfer personal data to third parties, intermediaries in particular, to the extent necessary for the Website administration to perform its duties as part of the Website administration’s business activities.
8.6. This Policy is to be updated if Russian Federation legislation on personal data changes.