This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” hereinafter referred to as the “Personal Data Law” and determines the procedure for processing personal data and the measures taken to ensure the security of personal data by Razvitie LLC hereinafter referred to as the “Operator”.

1.1. The Operator considers compliance with human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrets, to be its most important objective and a prerequisite for carrying out its activities.

1.2.This Policy of the Operator regarding the processing of personal data hereinafter referred to as the “Policy” applies to all information that the Operator may obtain about visitors of the website https://contrast-cleaners.ru/en/konfidenczialnost.

2.1. Automated processing of personal data means the processing of personal data using computer technology.

2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is necessary to clarify personal data.

2.3. Website means a collection of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://contrast-cleaners.ru.

2.4. Personal data information system means a set of personal data contained in databases, as well as information technologies and technical means that enable the processing of such data.

2.5. Depersonalization of personal data means actions as a result of which it becomes impossible, without using additional information, to determine whether personal data belongs to a specific User or another personal data subject.

2.6. Processing of personal data means any action or set of actions performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification, updating, modification, extraction, use, transfer, distribution, provision, access, depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator means a state authority, municipal authority, legal entity, or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the scope of personal data to be processed, and the actions or operations performed with personal data.

2.8. Personal data means any information directly or indirectly relating to an identified or identifiable User of the website https://contrast-cleaners.ru/en/konfidenczialnost.

2.9. Personal data permitted by the personal data subject for distribution means personal data to which access is granted to an unlimited number of persons by the personal data subject through consent to the processing of personal data permitted for distribution in accordance with the procedure established by the Personal Data Law hereinafter referred to as “personal data permitted for distribution”.

2.10. User means any visitor of the website https://contrast-cleaners.ru/en/konfidenczialnost.

2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite group of persons, including the transfer of personal data, or at making personal data available to an unlimited number of persons, including publication in the mass media, placement in information and telecommunication networks, or granting access to personal data by any other means.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to a foreign state authority, foreign individual, or foreign legal entity.

2.14. Destruction of personal data means any actions as a result of which personal data is irreversibly destroyed and the content of personal data in the personal data information system cannot be further restored, and/or physical media containing personal data are destroyed.

3.1. The Operator has the right to:

— receive from the personal data subject accurate information and/or documents containing personal data;
— if the personal data subject withdraws consent to the processing of personal data, continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;
— independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

— provide the personal data subject, at their request, with information concerning the processing of their personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
— provide the authorized body for the protection of the rights of personal data subjects, upon request, with the necessary information within 30 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions in relation to personal data;
— cease the transfer, distribution, provision, and access to personal data, cease processing, and destroy personal data in the manner and cases provided for by the Personal Data Law;
— perform other duties provided for by the Personal Data Law.

4.1. Personal data subjects have the right to:

— receive information concerning the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided to the personal data subject by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are lawful grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
— require the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights;
— set a condition of prior consent when personal data is processed for the purpose of promoting goods, works, and services on the market;
— withdraw consent to the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or to a court against unlawful actions or omissions of the Operator in the processing of their personal data;
— exercise other rights provided for by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

— provide the Operator with accurate personal data about themselves;
— notify the Operator of any clarification, update, or change to their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without the consent of the latter shall be liable in accordance with the legislation of the Russian Federation.

5.1.Year, month, date, and place of birth.

5.2. The website also collects and processes depersonalized data about visitors, including cookies, using Internet statistics services such as Yandex Metrica, Google Analytics, and others.

5.3. The data listed above are hereinafter collectively referred to in this Policy as Personal Data.

5.4. The Operator does not process special categories of personal data relating to race, nationality, political opinions, religious or philosophical beliefs, or intimate life.

5.5. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is permitted if the prohibitions and conditions provided for by Article 10.1 of the Personal Data Law are observed.

5.6. The User’s consent to the processing of personal data permitted for distribution shall be executed separately from other consents to the processing of their personal data. In doing so, the conditions provided for, in particular, by Article 10.1 of the Personal Data Law shall be observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

5.6.1. The User provides consent to the processing of personal data permitted for distribution directly to the Operator.

5.6.2. The Operator is obliged, no later than three business days from the receipt of the User’s consent, to publish information on the processing conditions, the existence of prohibitions, and the conditions for processing by an unlimited number of persons of personal data permitted for distribution.

5.6.3. The transfer, distribution, provision, and access to personal data permitted by the personal data subject for distribution must be terminated at any time at the request of the personal data subject. Such request must include the surname, first name, patronymic if applicable, contact information such as telephone number, email address, or postal address of the personal data subject, as well as a list of personal data whose processing must be terminated. The personal data specified in such request may be processed only by the Operator to whom the request is addressed.

5.6.4. Consent to the processing of personal data permitted for distribution shall cease to be valid from the moment the Operator receives the request specified in Clause 5.6.3 of this Personal Data Processing Policy.

6.1. Personal data shall be processed on a lawful and fair basis.

6.2. Personal data processing shall be limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes for which personal data was collected is not permitted.

6.3. It is not permitted to combine databases containing personal data where the processing is carried out for purposes incompatible with each other.

6.4. Only personal data that corresponds to the purposes of processing shall be processed.

6.5. The content and scope of the personal data being processed shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes of processing is not permitted.

6.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of personal data processing shall be ensured. The Operator shall take necessary measures and/or ensure that such measures are taken to delete or clarify incomplete or inaccurate data.

6.7. Personal data shall be stored in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or depersonalized upon achievement of the processing purposes or if the need to achieve such purposes is lost, unless otherwise provided by federal law.

7.1. The purposes of processing the User’s personal data are:

— informing the User by sending emails;
— concluding, performing, and terminating civil law contracts;
— providing the User with access to services, information, and/or materials contained on the website https://contrast-cleaners.ru/en/konfidenczialnost

7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User may at any time opt out of receiving informational messages by sending an email to the Operator at info@contrast-cleaners.ru with the subject line “Opt-out from notifications about new products, services, and special offers”.

7.3. Depersonalized data of Users collected through Internet statistics services is used to collect information about Users’ actions on the website and to improve the quality of the website and its content.

8.1. The legal grounds for the processing of personal data by the Operator are:

— regulatory legal acts governing relations related to the Operator’s activities; for example, if the Operator’s activities are related to information technologies, including website development, Federal Law No. 149-FZ dated July 27, 2006 “On Information, Information Technologies and Information Protection” may be specified here;
— the Operator’s charter documents;
— agreements concluded between the Operator and the personal data subject;
— federal laws and other regulatory legal acts in the field of personal data protection;
— Users’ consents to the processing of their personal data and to the processing of personal data permitted for distribution.

8.2. The Operator processes the User’s personal data only if such data is completed and/or submitted by the User independently through special forms located on the website https://contrast-cleaners.ru or sent to the Operator by email. By completing the relevant forms and/or sending their personal data to the Operator, the User expresses consent to this Policy.

8.3. The Operator processes depersonalized data about the User if this is permitted in the User’s browser settings, including enabled cookie storage and use of JavaScript technology.

8.4. The personal data subject independently decides whether to provide their personal data and gives consent freely, of their own will, and in their own interest.

9.1. Personal data shall be processed with the consent of the personal data subject to the processing of their personal data.

9.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, or to exercise the functions, powers, and duties imposed on the Operator by the legislation of the Russian Federation.

9.3. Personal data processing is necessary for the administration of justice or the enforcement of a judicial act, act of another authority, or official act subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. Personal data processing is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

9.5. Personal data processing is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not violated.

9.6. Personal data is processed where access to such data has been granted to an unlimited number of persons by the personal data subject or at their request, hereinafter referred to as publicly available personal data.

9.7. Personal data is processed where such data is subject to publication or mandatory disclosure in accordance with federal law.

This Privacy Policy regulates the collection, use, transfer, and protection of information of companies with which we cooperate when using our mobile application, website, and in connection with participation in promotions and advertising events aimed at promoting the “Contrast” trademark, as well as your ability to manage the collection and use of your information.

This Privacy Policy determines the procedure for the collection, use, transfer, and protection of information carried out by the Organizer and a number of partner companies during the use of the mobile application, website, and as part of participation in advertising campaigns and events related to the promotion of the “Contrast” trademark. The document also sets out the rights and options for managing the collection and use of information.

The security 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 current legislation in the field of personal data protection.

10.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

10.2. The User’s personal data shall never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or where the personal data subject has given consent to the Operator to transfer the data to a third party for the performance of obligations under a civil law contract.

10.3. If inaccuracies are identified in personal data, the User may update them independently by sending a notification to the Operator’s email address at info@contrast-cleaners.ru with the subject line “Personal Data Update”.

10.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by an agreement or current legislation.

The User may withdraw consent to the processing of personal data at any time by sending a notification to the Operator by email at info@contrast-cleaners.ru with the subject line “Withdrawal of Consent to Personal Data Processing”.

10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by such persons, operators, in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User is obliged to familiarize themselves with such documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

10.6. Restrictions established by the personal data subject on transfer, except for granting access, as well as on processing or processing conditions, except for obtaining access, of personal data permitted for distribution shall not apply in cases where personal data is processed in state, public, or other public interests defined by the legislation of the Russian Federation.

10.7. The Operator ensures the confidentiality of personal data when processing personal data.

10.8. The Operator stores personal data in a form that allows identification of the personal data subject for no longer than required by the purposes of personal data processing, unless the storage period for personal data is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.

10.9. The condition for terminating personal data processing may be the achievement of the purposes of personal data processing, expiration of the personal data subject’s consent, withdrawal of consent by the personal data subject, or identification of unlawful personal data processing.

11.1. The Operator performs collection, recording, systematization, accumulation, storage, clarification, updating, modification, extraction, use, transfer, distribution, provision, access, depersonalization, blocking, deletion, and destruction of personal data.

11.2. The Operator carries out automated processing of personal data with or without receipt and/or transfer of the information obtained via information and telecommunication networks.

12.1. Before carrying out cross-border transfer of personal data, the Operator is obliged to ensure that the foreign state to whose territory the personal data is intended to be transferred provides reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only with the written consent of the personal data subject to the cross-border transfer of their personal data and/or for the performance of an agreement to which the personal data subject is a party.

The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

14.1. The User may obtain any clarifications on issues of interest concerning the processing of their personal data by contacting the Operator by email at info@contrast-cleaners.ru.

14.2. Any changes to the Operator’s Personal Data Processing Policy shall be reflected in this document. The Policy shall remain in effect indefinitely until replaced by a new version.

14.3. The current version of the Policy is freely available on the Internet at: https://contrast-cleaners.ru/en/konfidenczialnost