Privacy policy

Operator: Limited Liability Company “Innovatione”, OGRN 1167746897262, INN 7723475810, 151 Lyublinskaya St., office 328/1, Moscow, Russia.

1. General provisions

This personal data processing policy has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the Personal Data Law). It sets out how personal data are processed and the measures taken to keep them secure by Limited Liability Company “Innovatione” (the Operator).

1.1. The Operator’s most important aim and condition of its activity is to respect human and civil rights and freedoms when processing personal data, including the protection of the rights to privacy and to personal and family secrets.

1.2. This Operator’s personal data processing policy (the Policy) applies to all information that the Operator may obtain about visitors to the website innovatione.com.

2. Basic terms used in the Policy

2.1. Automated processing of personal data: processing of personal data using computer technology.

2.2. Blocking of personal data: temporary suspension of the processing of personal data (except where processing is necessary to clarify the personal data).

2.3. Website: the set of graphic and information materials, computer programs and databases that make them available on the internet at innovatione.com.

2.4. Personal data information system: the set of personal data contained in databases and the information technologies and technical means used to process them.

2.5. Depersonalisation of personal data: actions that make it impossible, without additional information, to determine which specific User or other subject the personal data belong to.

2.6. Processing of personal data: any action or set of actions performed with personal data, with or without automation, including collection, recording, systematisation, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction of personal data.

2.7. Operator: a state body, municipal body, legal entity or individual that, alone or jointly with others, organises and/or carries out the processing of personal data, and determines the purposes of processing, the composition of the personal data to be processed and the actions performed with them.

2.8. Personal data: any information relating directly or indirectly to an identified or identifiable User of the website innovatione.com.

2.9. Personal data authorised by the subject for distribution: personal data to which the subject has given access to an unlimited number of persons by consenting to such processing in the manner provided by the Personal Data Law (personal data authorised for distribution).

2.10. User: any visitor to the website innovatione.com.

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

2.12. Distribution of personal data: any actions aimed at disclosing personal data to an indefinite number of persons (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 providing access to personal data in any other way.

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

2.14. Destruction of personal data: any actions that irreversibly destroy personal data, making further recovery of their content in the personal data information system impossible, and/or that destroy the physical media containing the personal data.

3. Main rights and obligations of the Operator

3.1. The Operator has the right to:

– obtain reliable information and/or documents containing personal data from the personal data subject;

– continue processing personal data without the subject’s consent where the subject withdraws consent, if there are grounds provided by the Personal Data Law;

– determine independently the composition and list of measures necessary and sufficient to fulfil the obligations provided by the Personal Data Law and the regulations adopted under it, unless otherwise provided by law.

3.2. The Operator must:

– provide the personal data subject, on request, with information about the processing of their personal data;

– organise the processing of personal data in the manner established by the current legislation of the Russian Federation;

– respond to requests and enquiries from personal data subjects and their legal representatives in accordance with the Personal Data Law;

– report the necessary information to the authorised body for the protection of the rights of personal data subjects, at its request, within 30 days of receiving the request;

– publish this Policy or otherwise provide unrestricted access to it;

– take legal, organisational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution and other unlawful actions;

– stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and in the cases provided by the Personal Data Law;

– perform other duties provided by the Personal Data Law.

4. Main rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:

– receive information about the processing of their personal data, except in cases provided by federal laws. The Operator provides this information in an accessible form, and it must not contain personal data relating to other subjects unless there are legal grounds for disclosing such data. The list of information and the procedure for obtaining it are set by the Personal Data Law;

– require the operator to clarify, block or destroy their personal data if the data are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;

– set a condition of prior consent for the processing of personal data for the purpose of promoting goods, works and services on the market;

– withdraw consent to the processing of personal data;

– appeal against unlawful actions or inaction of the Operator in processing their personal data to the authorised body for the protection of the rights of personal data subjects or in court;

– exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects must:

– provide the Operator with reliable information about themselves;

– inform the Operator of clarifications (updates, changes) to their personal data.

4.3. Persons who have given the Operator false information about themselves, or information about another personal data subject without the latter’s consent, are liable in accordance with the legislation of the Russian Federation.

5. Personal data of the User that the Operator may process

5.1. Last name, first name, patronymic.

5.2. Email address.

5.3. Phone numbers.

5.4. The site also collects and processes depersonalised data about visitors (including cookies) using web analytics services (Yandex Metrica).

5.5. The above data are hereinafter referred to collectively as Personal Data.

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

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

5.8. The User’s consent to the processing of personal data authorised for distribution is given separately from other consents to the processing of their personal data. The conditions provided, in particular, by Article 10.1 of the Personal Data Law are observed. Requirements for the content of such consent are set by the authorised body for the protection of the rights of personal data subjects.

5.8.1. The User gives consent to the processing of personal data authorised for distribution directly to the Operator.

5.8.2. No later than three working days after receiving such consent, the Operator must publish information on the processing conditions and on any prohibitions and conditions on the processing of personal data authorised for distribution by an unlimited number of persons.

5.8.3. The transfer (distribution, provision, access) of personal data authorised for distribution must be stopped at any time at the request of the personal data subject. The request must include the subject’s last name, first name, patronymic (if any), contact information (phone number, email or postal address) and the list of personal data whose processing is to be stopped. The personal data specified in the request may be processed only by the Operator to whom it is addressed.

5.8.4. Consent to the processing of personal data authorised for distribution ceases to apply from the moment the Operator receives the request specified in clause 5.8.3 of this Policy in respect of the processing of personal data.

6. Principles of personal data processing

6.1. Personal data are processed on a lawful and fair basis.

6.2. Processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing that is incompatible with the purposes of collecting personal data is not allowed.

6.3. Databases containing personal data processed for incompatible purposes may not be combined.

6.4. Only personal data that meet the purposes of their processing are processed.

6.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not allowed.

6.6. When personal data are processed, their accuracy, sufficiency and, where necessary, relevance to the purposes of processing are ensured. The Operator takes the necessary measures and/or ensures that they are taken to delete or clarify incomplete or inaccurate data.

6.7. Personal data are stored in a form that allows the personal data subject to be identified, for no longer than the purposes of processing require, unless the storage period is set by federal law or by a contract to which the subject is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalised when the purposes of processing are achieved or when there is no longer a need to achieve them, unless otherwise provided by federal law.

7. Purposes of personal data processing

7.1. The purpose of processing the User’s personal data is:

– informing the User by sending emails;

– concluding, performing and terminating civil law contracts;

– providing the User with access to the services, information and/or materials on the website innovatione.com.

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 can always opt out of such messages by sending an email to the Operator at russia@innovatione.ru marked “Opt-out of notifications about new products, services and special offers”.

7.3. Depersonalised data of Users collected through web analytics services are used to gather information about the actions of Users on the site and to improve the quality of the site and its content.

8. Legal grounds for processing personal data

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

– the Operator’s charter (constituent) documents;

– contracts concluded between the operator and the personal data subject;

– federal laws and other regulations in the field of personal data protection;

– Users’ consent to the processing of their personal data and of personal data authorised for distribution.

8.2. The Operator processes the User’s personal data only if the User fills in and/or sends them independently through the special forms on the website innovatione.com or sends them to the Operator by email. By filling in the relevant forms and/or sending their personal data to the Operator, the User agrees to this Policy.

8.3. The Operator processes depersonalised data about the User if this is allowed in the settings of the User’s browser (cookies and JavaScript are enabled).

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

9. Conditions for processing personal data

9.1. Personal data are processed with the consent of the personal data subject.

9.2. Processing of personal data is necessary to achieve the purposes provided by an international treaty of the Russian Federation or by law, and to perform the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.

9.3. Processing of personal data is necessary for the administration of justice and the execution of a judicial act or an act of another body or official that is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. Processing of personal data is necessary for the performance of a contract to which the personal data subject is a party, beneficiary or guarantor, and for concluding a contract on the initiative of the subject or a contract under which the subject will be a beneficiary or guarantor.

9.5. 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 personal data subject are not violated.

9.6. Personal data are processed to which access has been given to an unlimited number of persons by the personal data subject or at their request (publicly available personal data).

9.7. Personal data subject to publication or mandatory disclosure under federal law are processed.

10. Collection, storage, transfer and other processing of personal data

The security of personal data processed by the Operator is ensured by implementing the legal, organisational and technical measures necessary to fully meet 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 unauthorised persons.

10.2. The User’s personal data will 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 consented to the Operator transferring the data to a third party to perform obligations under a civil law contract.

10.3. If inaccuracies in personal data are found, the User can update them by sending a notice to the Operator’s email address russia@innovatione.ru marked “Updating personal data”.

10.4. The period of personal data processing is determined by the achievement of the purposes for which the data were collected, unless another period is provided by contract or current legislation. The User may withdraw consent to the processing of personal data at any time by sending a notice to the Operator by email at russia@innovatione.ru marked “Withdrawal of consent to the processing of personal data”.

10.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by those persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User must review those documents in good time. The Operator is not responsible for the actions of third parties, including the service providers named in this clause.

10.6. Prohibitions set by the personal data subject on the transfer (other than providing access) and on the processing or conditions of processing (other than obtaining access) of personal data authorised for distribution do not apply to processing in state, public and other public interests determined by the legislation of the Russian Federation.

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

10.8. The Operator stores personal data in a form that allows the personal data subject to be identified, for no longer than the purposes of processing require, unless the storage period is set by federal law or by a contract to which the subject is a party, beneficiary or guarantor.

10.9. Processing of personal data may be terminated when the purposes of processing are achieved, when the period of the personal data subject’s consent expires, when the subject withdraws consent, or when unlawful processing of personal data is identified.

11. Actions performed by the Operator with personal data received

11.1. The Operator collects, records, systematises, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, gives access to), depersonalises, blocks, deletes and destroys personal data.

11.2. The Operator carries out automated processing of personal data, with or without receiving and/or transferring the information obtained over information and telecommunication networks.

12. Cross-border transfer of personal data

12.1. Before starting a cross-border transfer of personal data, the Operator must make sure that the foreign state to whose territory the data are to be transferred provides reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data to foreign states that do not meet the above requirements may take place only with the written consent of the personal data subject to such transfer and/or for the performance of a contract to which the subject is a party.

13. Confidentiality of personal data

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

14. Final provisions

14.1. The User can obtain any explanations on matters relating to the processing of their personal data by contacting the Operator by email at russia@innovatione.ru.

14.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy remains in force indefinitely until it is replaced by a new version.

14.3. The current version of the Policy is freely available on the internet at innovatione.com/en/privacy.