Privacy policy
Date of placement 06.08.2021


This Privacy policy (hereinafter referred to as the Policy) defines the general principles and procedure for processing of the Personal Data of the Website Users and measures to ensure their security accepted by the Limited Liability Company “Platrum”.


TERMS AND DEFINITIONS

Parties use the following terms in the following meaning:

Data – any other data about the User (not included in the definition of Personal Data).

Legislation - legislation of the Russian Federation in force.

Operator – LLC «Platrum», organizing the processing and (or) processing of Personal Data, independently or jointly with other persons, as well as determining the purposes of Personal Data processing, the composition of Personal Data to be processed, actions (operations) performed with Personal Data.


Personal Data - any information relating to an identified or identifiable natural person (User).



User - a person who has passed the registration procedure on the Site and has access to the Site via the Internet.

Transmission of personal data - actions aimed at Personal data disclosure to a specific person or a certain circle of persons.


Site - the web-site owned by the Operator and located on the Internet at https://platrum.ru/


Personal Data Subject is the User (natural person) to whom the Personal Data relates.



1. GENERAL PROVISIONS

1.1. The Privacy Policy is created in accordance with the provisions of the Russian Federal Law dated July 27, 2006 No. 152-ФЗ “On Personal Data” (with amendments and additions), other legislative and regulatory legal acts to determine the procedure for processing of the Personal Data of the Users and (or) transmitted by the Users and the requirements for ensuring their safety.


1.2. Measures to ensure the security of the Personal Data are an integral part of the Operator’s activities.


2. PRINCIPLES RELATING TO PROCESSING OF PERSONAL DATA

2.1. The processing of the Personal Data by the Operator is carried out in accordance with the following principles:

2.1.1. Lawfullnes of processing of the Personal Data. The Operator takes all necessary measures to comply with the requirements of the Legislation, does not process the Personal Data in cases where this is not allowed by the Legislation, does not use the Personal Data to the detriment of the User.


2.1.2. Processing of the Personal Data meets the declared purposes of processing. Compliance of the content and scope of the Personal Data in processing with the specified processing purposes. The Operator prevents the processing of the Personal Data incompatible with the purposes of collecting the Personal Data, as well as processing of the Personal data that are excessive in relation to the specified purposes of the processing. The Operator processes the Personal Data solely for the purposes specified in paragraph 4.2 of the Policy.

2.1.3. Ensuring the accuracy, sufficiency and relevance of the Personal Data in relation to the purposes of processing. The Operator takes all reasonable measures to maintain the relevance of the Personal Data being processed, including but not limited to the exercise of the Data Subject right to receive information relating to processing to the data subject and require the Operator to specify, block or destroy (delete) the Personal Data if the Personal Data are incomplete, out-dated, inaccurate, illegally obtained or not necessary for the specified processing purposes.



2.1.4. Storage of the Personal Data in a form that allows to define a User of Personal Data no longer than the purpose of the Personal Data processing requires, unless the period of storage of the Personal Data is established by federal law, a contract to which the User is a party or a beneficiary.



2.1.5. Inadmissibility of combining of the Personal Data information systems created for incompatible purposes of the databases.



3. CONDITIONS OF THE PERSONAL DATA PROCESSING

3.1. Processing of the Personal Data by the Operator is allowed in the following cases:

3.1.1. A consent of the User is given for the processing of the Personal Data related to the User. The consent is given by filling out an electronic form located on the Site and activating the check box.

3.1.2. The Personal data are subject to publication or mandatory disclosure in accordance with the Legislation.

3.2. The Operator does not disclose to third parties and does not distribute the Personal Data without the consent of the User, unless otherwise provided by the Legislation.

3.3. The Operator does not process of special categories of the Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, concerning health or the Personal Data Subject’s sex life or sexual orientation, public associations membership , except as expressly provided for by the Legislation.



3.4. By providing Users the opportunity to use the Site, the Operator, acting reasonably and in good faith, believes that the User:


3.4.1. Has all the necessary rights that allow him to register and log in to the Site and use it.


3.4.2. Realizes that certain types of information transmitted to them by other Users cannot be deleted by the User.

3.5. The Operator does not verify the accuracy of the received (collected) information about the Users, except in cases where such verification is necessary in order to comply with the provisions of applicable law and / or obligations to the User.



4. PROCESSING OF THE PERSONAL DATA AND OTHER DATA

4.1. The Operator processes the Personal Data in order to:

4.1.1. Inform the User about the services of the Operator or partners of the Operator, including sending informational letters and advertising mailings..

4.1.2. Conclude an agreement between the Operator and the User.

4.1.3. Fulfill the Operator’s contractual obligations to the User.

4.1.4. Conduct statistical and other studies based on anonymous personal data.


4.2. The Operator processes the following Personal Data:
a. Name;
b. Surname;
c. Middle name
d. E-mail address;
e. Phone;
f. Identification data in Slack;
g. Identification data in Skype;
h. Identification data in Telegram;
i. Profile photo
j. IP address;
k. Payment details;
l. Cookies.

4.3. The Operator processes the following other information / data:

4.3.1. Standard technical and other data automatically obtained by the Operator when the User accesses the Site and subsequent User actions on the Site (location at a certain point in time, IP address, type of operating system of the User’s device, sections of the Site visited by the User).


4.3.2. Information obtained as a result of the User’s actions on the Site.

4.3.3. Information obtained as a result of actions of other Users on the Site.

4.4. With respect to the Personal Data and other Data, their confidentiality is preserved, unless the specified data is publicly available.


4.5. The Operator has the right to keep an archive copy of the Personal Data and other Data, including keeping it after deleting the User’s account.

4.6. The Operator has the right to transfer the Personal Data and Data without the consent of the User to the following persons:


4.6.1. To state bodies, including bodies of inquiry and investigation, and bodies of local government upon their motivated request.


4.6.2. Partners of the Operator in order to fulfill contractual obligations to the User.

4.6.3. In other cases expressly provided for by the current legislation of the Russian Federation.

4.7. The Operator has the right to transfer the Personal Data and other Data to third parties not specified in paragraph 4.6 of this Policy in the following cases:

4.7.1. User has consented to such actions.


4.7.2. The transfer is required as part of the User’s use of the Site.

4.7.3. The transfer takes place as part of the sale or other transfer of the business (in whole or in part), and all obligations to comply with the terms of this Policy are transferred to the acquirer.

4.8. The Operator performs automated and non-automated processing of the Personal Data and other Data.

4.9. Access to information systems containing the Personal Data is provided by a password system. Passwords are set by authorized employees of the Operator and are individually disclosed to employees of the Operator who have access to the Personal Data / the Data.

4.10. The User has the right to revoke his consent to the processing of Personal Data at any time. Upon receipt of the request the Operator shall, within thirty (30) calendar days of its receipt, erase the Personal Data. The Personal Data of the User is erased from the Site when the Operator deletes the information posted by the User, as well as the User’s Personal Account at the request of the User or on his own initiative in the cases provided for in the License Agreement. After the removal of the User’s Personal data from the Site, the Operator stores them on electronic medium for the period established by the legislation of the Russian Federation.






4.11. The Site uses the cookie technology - small text files placed on User's devices in order to analyse the User’s activity. The information collected by the cookie cannot be used to identify the User. The Operator will process this information to assess the use of the Site by the User, to compile reports on the activities of the Site. The User may refuse the use of cookies by selecting the appropriate settings in the browser, but this may affect the operation of some functions of the Site.



4.12. The term for processing of the Personal Data is equal to the term for fulfilling obligations between the User and the Operator, the period for interaction between the User and the Operator, another term provided for in the User’s consent to the processing of the Personal Data. After the expiration of the time specified in this clause, the Operator is entitled to process the Personal Data for 1 (one) year, but in any case no later than the moment when the Subject withdraws the Personal Data.

4.13. The Personal Data are stored on servers located on the territory of the Russian Federation.

4.14. The User gives the Operator consent to the cross-border transfer of the Personal Data.


5. CHANGE OF THE PERSONAL DATA

5.1. The user may at any time change (update, amend)the Personal Data, information about the User in his Personal Account on the Site, provided that such changes and corrections contain relevant and reliable information by sending a written request to the Operator or making changes in his Personal Account online.


5.2. The User has the right to delete the Personal Data / Data at any time.


6. CONFIDENTIALITY OF THE PERSONAL DATA

6.1. The Operator shall ensure the confidentiality of the Personal Data / Data processed in the manner prescribed by the Legislation. Confidentiality is not required for:

6.1.1.The Personal Data after their depersonalization;

6.1.2. The Personal Data, accessible to an unlimited number of persons if such access is provided by the User or at his request (hereinafter - Personal data made publicly available by the User);

6.1.3. The Personal Data that is subject to publication or mandatory disclosure in accordance with the Legislation.

6.2. It does not violate the confidentiality of the Personal Data if they are provided by the Operator to third parties acting on the basis of an agreement with the Operator to fulfill contractual obligations to the User.


6.3. Ensuring the security of personal data is achieved, in particular, but not limited to the following actions:

6.3.1. Identifying threats to the security of the Personal Data when they are processed in the personal data information systems;


6.3.2. Adoption of organizational and technical measures to ensure the security of the Personal Data during their processing in the personal data information systems necessary to meet the requirements for the protection of the Personal Data;





6.3.3. Application of the procedure for assessing the compliance of information security tools in accordance with the established procedure;

6.3.4. Evaluation the effectiveness of measures taken to ensure the security of the Personal Data prior to the exploitation of the personal data information system;


6.3.5. Audit electronic personal data mediums;


6.3.6. Detection of unauthorized access to the Personal Data and taking relative action;


6.3.7. Restoration of Personal Data modified or destroyed due to unauthorized access to one;


6.3.8. establishment of rules for access to the Personal Data processed in the personal data information system, as well as ensuring the registration and recording of all actions performed with the Personal Data in the personal data information system;


6.3.9. Control over measures taken to ensure the security of the Personal Data and the level of security of the personal data information systems.

6.3.10. Other measures to ensure the confidentiality of the Personal Data.


7. USER CONSENT FOR THE PERSONAL DATA PROCESSING

7.1. The User decides to provide the Personal Data to the Operator and agrees to process them freely, by his/her own will and in his/her interest. The Consent to the processing of the Personal Data must be specific, informed and conscious and provided by the User at the time of his registration on the Operator’s Site or at the time of filling in the relevant electronic form, as well as in any form allowing to confirm the fact of its receipt, unless otherwise provided by the Legislation.



7.2. The Personal data of persons entered into contractual obligations with the Operator, contained in the Unified State Register of legal entities and individual entrepreneurs (or other relevant register), is open and publicly available, with the exception of information about the number, date of issue and the authority that issued the identity document of an individual. Protection of their confidentiality and the consent of Users for processing is not required.

7.3. In the case of requests from organizations that do not have the appropriate authority, the Operator is obliged to obtain the prior consent of the User to provide the Personal Data and warn those receiving Personal Data that this data can only be used for the purposes for which they were transferred to the Operator, and also to demand confirmation that this rule will be (was) observed.



7.4. By agreeing to process the Personal Data, the User confirms that he/she has reached the age of 16.


8. RIGHTS OF THE PERSONAL DATA SUBJECTS

8.1. The User has the right to receive information concerning the processing of the Personal Data / Data. The User has the right to require the Operator to clarify the Personal Data, to block or destroy them if the Personal Data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take legal measures to protect his/her rights. The User has the right to copy, transfer the Personal Data to another platform / service.




8.2. If the User believes that the Operator processes the Personal Data in violation of the requirements of the Legislation or otherwise violates his rights and freedoms, the User has the right to appeal against the actions or omissions of the Operator to the authorized body for the protection of the rights of the Personal Data Subjects or in court.



9. PERSONAL DATA OF THIRD PARTIES USED BY USERS.

9.1. Using the Site, the User has the right to fill in the data of third parties to receive distribution of promotional materials and information.

9.2. The User undertakes to obtain the prior consent of the Personal Data Subject to use the Site. The User is solely responsible for the absence of such consent and is obliged to compensate the Operator for the losses occurred due to the absence of consent.



9.3. The Operator undertakes to take the necessary measures to ensure the safety of the Personal Data of third parties entered by the User.


10. OTHER PROVISIONS

10.1. The law of the Russian Federation is the governing law to this Policy and to the relationship between the User and the Operator arising in connection with the application of the Policy.

10.2. All possible disputes are subject to resolution in accordance with the Legislation at the place of registration of the Operator. Before applying to court, the User must follow the mandatory pre-trial procedure and send the relevant claim to the Operator in writing. The deadline for responding to a claim is 30 (thirty) business days.


10.3. If for any reason any provision of the Privacy Policy is deemed invalid or unenforceable, it does not affect the validity or applicability of the remaining provisions of the Privacy Policy.


10.4. The Operator has the right at any time to change this Privacy Policy (in whole or in part) unilaterally without prior approval from the User. All changes take effect the next day after posting on the Site.


10.5. The User undertakes to independently monitor the changes in the Privacy Policy by acquainting the current edition.



11. CONTACT INFORMATION OF THE OPERATOR

LLC «Platrum»
109004, Moscow, Alexander Solzhenitsyn str., 23a, building 1, floor 1, room III, 1D
OGRN (registration number): 1217700315260
TIN: 9709072756
To exercise their rights, the User has the right to contact the Operator by email support@platrum.ru