Confidentiality Policy


This document “Confidentiality Policy” (hereafter referred to as the “Policy”) provides rules of use of User’s personal data by the website: [Individual Entrepreneur (IP) A.V. Palagin] (hereafter referred to as the “Operator”) with regard to User’s personal data which can be obtained by the Operator, including all members of its group, can obtain when the User uses any Operator’s website, service, program or products (hereafter referred to as the “Website”) and in the process of performance of any agreements and contracts with the User by the Operator. User’s acceptance of the Policy expressed within the framework of relationship with one of the abovementioned parties, cover relationships with all other abovementioned parties.

Use of the Website constitutes unconditional acceptance of this Policy and terms and conditions of personal data processing provided herein by the User. If the User does not accept the terms and conditions, he/she must not use the Website.


  1. General Provisions of the Policy


1.1. This Policy is an integral part of the Public Offer (hereafter referred to as the “Offer”) posted and/or available in the Internet:, and any other agreements entered into with the User as long as it is provided in such agreements.

1.2. This Policy has been drawn in accordance with Federal Law No.152-FZ “On Personal Data” dated 27th July 2006 and other regulations of the Russian Federation regarding personal data protection and processing. The Policy applies to all personal data which the Operator may obtain from the User who is a party to the civil law contract.

1.3. The Operator is entitled to amend this Policy from time to time. If any amendments are made, the date of the last update shall be specified in the Policy title. Any revised Policy becomes effective as soon as it is posted on the Website unless otherwise provided in such revised Policy.

1.4. This Policy, including interpretation of its provisions and the procedures of adoption, execution, amendment and cancellation, shall be governed by the laws of the Russian Federation.


  1. Users’ Personal Data Processed by the Website


2.1. For the purpose of this Policy, personal data includes the following:

2.1.1.Information provided by the User independently when signing up (creating an account) or in the process of use of the Website, including User’s personal data. Information compulsory for use of the Website is highlighted. Other information is provided by the User at his/her own discretion;

2.1.2.Data automatically transmitted to the Website in the process of use by software installed on User’s device, including User’s IP-address, cookie files, information about User’s browser (or any other program with which the User accesses the Website), technical specifications of User’s hardware and software, date and time of access to the Website, addresses of pages requested, and any other similar information; and

2.1.3. Other User’s information which is to be processed in accordance with the terms and conditions of use of the Website.

2.2. This Policy applies only to information processed when the Website is used. The Website does not control and shall not be held responsible for processing of information by other websites which the User may visit following links available on the Website.

2.3. The Website does not verify User’s personal information and has no possibility to assess his/her legal capacity. 


3.Objectives of Processing of Users’ Personal Information


3.1. The Website collects and stores only personal information required to provide services or perform agreements and contracts entered into with the User unless any applicable law provides for compulsory storage of personal data for a particular period of time.

3.2. User’s personal information shall be processed by the Website in order to:

3.2.1. Identify the parties within the framework of services and agreements and contracts entered into with the Website;

2.2.2. Render personalized services to the User, and to perform relevant agreements and contracts;

2.2.3. Send notifications and requests and information regarding use of the Website, performance of agreements and contracts, and to process User’s requests and applications;

2.2.4. Improve performance of the Website and convenience of its use, and to develop new services;

2.2.5. Target advertising; and

2.2.6. Conduct statistical and any other analysis on the basis of depersonalized data.


  1. Terms and Conditions of Users’ Personal Data Processing and Transmitting Users’ Personal Data to Third Parties

4.1. The Website maintains confidentiality of User’s personal data unless the User provides his/her personal information for unlimited access by any other person.

4.2. The Website is entitled to transmit User’s personal information to any third party in the following events:

4.3.1. If the User has agreed to such transmission;

4.3.2. Such transmission is required for use of any particular service by the User or for performance of any particular agreement or contract with the User;

4.3.3. Such transmission is required to ensure functionality and serviceability of the Website;

4.3.4. Such transmission is provided for by any applicable law of the Russian Federation or any other country as a part of some legal procedure;

4.3.5. Data is transmitted within the framework of sale or any other transfer of the business (either in full or partially). At the same time, all obligations provided for by the terms and conditions of this Policy with regard to personal information shall be transferred to the purchasing party;

4.3.6. Such information is required to protect rights and legal interests of the Website or any third party if the User breaches the Website User Agreement, this Policy or provisions of other documents including provisions on use of particular services;

4.3.7. If the data transmitted has been de-personalized in processing and made statistical for the purpose of any survey and analysis, carrying out any works or rendering any services under instructions issued by the Website.


5.Making Changes to and Deletion of Personal Information

Compulsory Data Storage


5.1. At any moment of time the User may contact the Website in any way detailed in section 9 “Contact Details” applying for change (update or addition) of personal information or any of its part provided by the User.

5.2. The rights provided in Clause 5.1 of this Policy, can be restricted in accordance with legislative requirements. For instance, such restrictions can provide for obligation of the Website to store any changed or deleted by the User information for a term specified in applicable laws and to transmit such information following a legally established procedure to a competent governmental authority.


6.Personal Data Processing Using Cookie Files and Counters  

6.1. Cookie files transmitted by the Website of User’s PC or mobile device and by User’s PC or mobile device to the Website can be use by the latter to render personalized services to the User, target advertising displayed to the User, to conduct statistical and other survey and analysis and to improve the Website.

6.2. The User recognizes that any hardware and software used by him/her to visit Internet websites can feature a function blocking operations with cookie files (for any websites or for specific websites) and deleting cookie files which were received earlier.

6.3. Yandex is entitled to set a rule according to which particular services can be rendered only providing that the User allows sharing cookie files.

6.4. The structure, content and technical parameters of cookie files are determined by the Website and can be changed without prior notification of the User.

6.5. Website counters can be used to analyze User’s cookie files, to collect and process statistical information about use of the Website, to ensure proper performance of the Website or any of its functions. Technical parameters of such counters are determined by the Website and can be changes without prior notification of the User.  


7.Protection of User’s Personal Information

7.1. The Website takes any and all required and adequate organizational and technical measures to protect User’s personal information against illegal or unauthorized access, destruction, changing, blocking, copying, distribution and any other illegal actions taken by third parties.

  1. Amendments to the Confidentiality Policy


8.1. The Website is entitled to amend this Confidentiality Policy. If any amendments are made, the current version of the Policy shall contain the date of the latest update. Any amended version of the Policy comes into effect as soon as it is posted unless otherwise provided in such amended version. The current version of the Policy is always available on the page:


9.Contact Details and Questions on Personal Data


9.1. Should you have any proposals, questions, requests or any other messages with regard to this Policy and use of your personal data, please do not hesitate to contact us:

-By e-mail:; or

-By mail: Off. 398, # 32/2, Golubinskaya str., Moscow 117463; Individual Entrepreneur (IP) A.B. Palagin.

Posted on: June 30, 2017

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