1. General Provisions
1.1. This Privacy Policy regarding the processing of personal data on the Internet has been prepared in accordance with paragraph 2 of Part 1 of Article 18.1 of the Federal Law of the Russian Federation No. 152-FZ of July 27, 2006 "On Personal Data" and defines the position of the International Consumer Cooperative "New Time" (hereinafter — ICC "New Time", the Cooperative, or the Company) regarding the processing and protection of personal data, the observance of the rights and freedoms of each personal data subject, and in particular, the right to privacy, personal and family secrets.
1.2. ICC "New Time", established as a legal entity under the legislation of the Russian Federation (Primary State Registration Number (OGRN): 1227700062347, Taxpayer Identification Number (INN): 9715413771) and registered at the legal address: Russia, Moscow, Goncharova Street, Building 9A, Floor/Premises 1/I, Room/Part of Room 6A/6, is the operator of personal data.
1.3. The Policy of ICC "New Time" regarding the processing of personal data is that personal data must be processed only in cases and in accordance with the procedure established by applicable law, on a lawful and fair basis. Respect for and protection of the rights and legitimate interests of personal data subjects is the top priority for ICC "New Time".
1.4. This Privacy Policy regarding the processing of personal data on the Internet uses the following terms, which may be written with uppercase or lowercase letters.
"Updating of personal data" means actions to clarify, update, and modify personal data aimed at ensuring the relevance of personal data in relation to the purposes of their processing.
"Blocking of personal data" means the temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
"Data" means personal data processed using the Website.
"Law" means Federal Law No. 152-FZ of July 27, 2006 "On Personal Data".
"Information System" means the totality of personal data contained in databases and the information technologies and technical means ensuring their processing.
"Company" means the International Consumer Cooperative "New Time", which is the operator of the Data.
"Confidentiality of personal data" means a mandatory requirement for a person who has gained access to personal data not to disclose such information to third parties without the consent of the data subject.
"Depersonalization of personal data" means actions that make it impossible, without the use of additional information, to determine the ownership of personal data to a specific personal data subject.
"Processing of personal data" means any action (operation) or set of actions (operations) performed with or without the use of automation means with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), depersonalization, blocking, deletion, and destruction of personal data.
"Operator" means a state body, municipal body, legal or natural person that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
"Person responsible for the processing of personal data" means an employee of the Company appointed as the Responsible Person for organizing the processing of personal data in the Company.
"Personal data" means any information relating directly or indirectly to a specifically identified or identifiable natural person (personal data subject).
"Policy" means this Policy regarding the processing of personal data.
"Users" means individuals (personal data subjects) who visit the Website and use its functionality.
"Provision of personal data" means actions aimed at disclosing personal data to a specific person or a specific group of persons.
"Employees" means individuals (personal data subjects) with whom the Company has an employment relationship.
"Roskomnadzor" means the authorized body for the protection of the rights of personal data subjects.
"Website" means the website located at www.iccnt.ru.
"Collection of personal data" means the purposeful process of obtaining personal data from the personal data subject.
"Personal data subject" means a natural person to whom the personal data relates.
"Cross-border transfer of personal data" means the transfer of personal data to the territory of a foreign state to a foreign operator.
"Destruction of personal data" means actions that make it impossible to restore the content of personal data in the information system and/or as a result of which the physical media of personal data are destroyed.
"Storage of personal data" means a process that involves keeping personal data in a systematized form at the disposal of the Company.
1.5. This Policy regulates only the issues of processing and protection of Users' Data when they use the Website, as well as Data of Employees posted on the Website. The processing and protection of personal data in all other cases is determined by the Company's internal regulations.
1.6. The Website contains links to other web resources belonging to the Company or other persons. This Policy does not apply to them. Users who follow links to other websites are advised to familiarize themselves with the privacy policies posted on such websites.
1.7. The User has the following basic rights:
the right to receive information concerning the processing of their Data;
the right to request clarification, blocking, or destruction of their Data if they are incomplete, outdated, inaccurate, illegally obtained, or are not necessary for the stated purpose of processing;
the right to appeal the actions (or inaction) of the Company to state authorities, including in court;
the right to protect their rights and legitimate interests, including compensation for damages and/or compensation for moral harm in court or in accordance with other procedures provided for by applicable law;
and other rights established by applicable law.
1.8. The Company, as the Data Operator, is entitled to process Data only in cases, to achieve purposes, and in compliance with other conditions established by the Law.
1.9. The Company has the following main obligations:
when collecting Data, the Company is obliged to provide the User, upon their request, with the information provided for in Part 7 of Article 14 of the Law;
if the provision of Data is mandatory in accordance with the law, the Company is obliged to explain to the User the legal consequences of refusing to provide their Data;
the Company is obliged to take necessary and sufficient measures to ensure the fulfillment of duties provided for by the Law and regulatory legal acts adopted in accordance with it;
the Company is obliged to publish this Policy on the Internet, information on the implemented requirements for the protection of personal data, and also to ensure access to this document via the Internet;
when processing personal data, the Company is obliged to take necessary legal, organizational, and technical measures or ensure their adoption to protect Data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions in relation to Data;
the Company is obliged to respond to requests from Users and inquiries from Roskomnadzor and provide them with information concerning the processing of Data in the manner established by the Law;
the Company is obliged to eliminate violations of the law committed during the processing of Data, clarify, block, and destroy Data (or ensure that these actions are carried out by a person acting on behalf of the Company);
the Company is obliged, before starting the processing of personal data, to notify Roskomnadzor of its intention to process personal data, except in cases established by law;
the Company is obliged to appoint a Person Responsible for the processing of personal data;
the Company bears other obligations provided for by law in connection with the processing of Data.
2. Purposes of Data Collection
2.1. The processing of Data must be limited to the achievement of specific, pre-defined, and lawful purposes. The processing of Data incompatible with the purposes of collecting personal data is not permitted.
2.2. The Company processes Data using the Website for the following purposes:
business communication with Users;
ordering, selling, and delivery of goods, and the acquisition of services;
providing a personal account on the Website;
distribution of advertising, informational materials, and news;
ensuring the operation of the forum;
additional purposes may be specified in the Users' consent to the processing of their Data, posted on the Website in a visible form (for example, in a web form designed for Data collection).
3. Legal Grounds for Data Processing
3.1. The legal basis for the processing of personal data is the set of legal acts under which and in accordance with which the operator processes personal data.
3.2. The legal grounds for processing Data using the Website are specified in Section 4.3 of this Policy.
4. Scope and Categories of Processed Data
4.1. The content and scope of the processed Data must correspond to the stated purposes of processing. The processed Data must not be excessive in relation to the stated purposes of their processing.
4.2. Special categories of personal data (for example, information on race, nationality, political views, religious or philosophical beliefs, health status), as well as biometric personal data, are not processed on the Website.
4.3. The following is information on the main categories and scope of processed Users' Data in relation to purposes, legal grounds, and processing periods.
| Categories of Users' Data | Purposes of Processing | Legal Grounds | Processing Periods |
|---|---|---|---|
| Last name, first name, patronymic; contact details (phone, email address); call time; order number; consumer preferences. | Business communication with Users | Consent to processing of personal data (clause 1, part 1, art. 6 of the Law) | Until the User's order is fully fulfilled |
| Last name, first name, patronymic; contact details (phone, email address); preferred call time; discount and/or bonus card details; delivery address; consumer preferences; name and details of the legal entity on whose behalf the User acts. | Ordering, selling, delivery of goods, and acquisition of services | Consent to processing of personal data (clause 1, part 1, art. 6 of the Law) | Until the expiration of the statute of limitations (3 years) after the Company and the User have fully fulfilled their obligations regarding the order, sale, and delivery of goods and acquisition of services |
| First name; contact details (email address). | Distribution of advertising, informational materials, and news | Consent to processing of personal data (clause 1, part 1, art. 6 of the Law) | Until the User withdraws consent to the processing of personal data |
| Pseudonym (forum name); password; contact details (email address); city of residence. | Ensuring the operation of the forum | Consent to processing of personal data (clause 1, part 1, art. 6 of the Law) | Until the User withdraws consent to the processing of personal data |
5. Procedure and Conditions for Data Processing
5.1. The Company processes Data using automation tools (including computers) and without the use of automation tools (including on paper). The Company may perform the following actions (operations) and/or set of actions (operations) with Data:
collection;
recording;
systematization;
accumulation;
storage;
clarification (updating, modification);
extraction;
use;
transfer (provision, access);
depersonalization;
blocking;
deletion;
destruction.
5.2. When collecting Users' Data using web forms, the Company always proceeds from the following:
all Data belongs personally to the User who filled out the web form;
the User followed the instructions for filling out the web form, including entering information in the sections specifically designated for them;
the User is legally capable and of legal age;
the User has provided accurate and up-to-date Data.
5.3. Users' Data is processed until the purpose of processing is achieved or until the User withdraws consent to the processing of their Data, unless other legal grounds for continuing the processing of Data exist. Processing periods may also be specified in the text of the consent to Data processing attached to the relevant web form.
5.4. The period and conditions for processing Employees' Data are determined by the legislation of the Russian Federation and the Company's internal regulations.
5.5. The Company may entrust the processing of Data to third parties by concluding an agreement with them for the processing of personal data. Subject to the conditions established by law, the Company also has the right to transfer Data to third parties for further independent processing. Third parties are obliged to comply with the requirements for the protection of the processed Data.
5.6. The Company does not carry out cross-border transfer of Data processed using the Website.
5.7. The Company transfers Data to courts, law enforcement, supervisory authorities, and other authorized state bodies and officials when there are grounds provided for by applicable law.
5.8. The Company recognizes Data as strictly confidential information. The Company and other persons who gain access to Data do not disclose Data to third parties or distribute Data without the consent of the relevant personal data subject, unless otherwise provided by federal law.
5.9. In accordance with Part 2 of Article 18.1 of the Law, the Company publishes this Policy, as well as information on the implemented requirements for Data protection (Appendix No. 1 to the Policy) on the Website and provides permanent, free, and unrestricted access to them for all Users.
5.10. The Company takes necessary legal, organizational, and technical measures or ensures their adoption to protect Data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, and other unlawful actions in relation to Data. Data security is ensured, in particular, by:
identifying threats to Data security during their processing in personal data information systems;
applying organizational and technical measures to ensure Data security during their processing in personal data information systems, necessary to meet the requirements for Data protection, the implementation of which ensures the levels of personal data security established by the Government of the Russian Federation;
applying information security tools that have passed the conformity assessment procedure in accordance with established procedures;
evaluating the effectiveness of measures taken to ensure Data security before the personal data information system is put into operation;
keeping records of machine-readable Data media;
detecting instances of unauthorized access to Data and taking measures;
restoring Data that has been modified or destroyed due to unauthorized access;
establishing rules for access to Data processed in the personal data information system, as well as ensuring the recording and accounting of all actions performed with Data in the personal data information system;
monitoring the measures taken to ensure Data security and the level of protection of personal data information systems.
5.11. Grounds for terminating the processing of Data may include achieving the purposes of Data processing, expiration of the consent period or withdrawal of consent by the personal data subject to the processing of their Data, as well as detection of unlawful processing of Data.
5.12. Data is stored in a form that allows the identification of the personal data subject for no longer than required by the purposes of Data processing, except in cases where the Data storage period is established by federal law, a contract to which the personal data subject is a party, beneficiary, or guarantor.
5.13. When collecting Data, the Company is obliged to ensure the recording, systematization, accumulation, storage, clarification (updating, modification), and extraction of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation, except in cases established by the Law.
5.14. The Company ensures storage conditions for Data that exclude unlawful or accidental access to them by implementing physical Data protection measures, as well as by conducting appropriate organizational measures.
5.15. The User of the Website may at any time withdraw their consent to the processing of Data by sending an electronic or written message in any form to the addresses specified in Section 8.14 of this Policy.
6. Updating, Correction, Deletion, and Destruction of Data, Responses to Requests for Access to Data
6.1. In the event of confirmation of the fact of inaccuracy of Data or unlawfulness of their processing, the Data shall be updated by the Company, and the processing shall be terminated accordingly.
6.2. Upon achievement of the purposes of Data processing, as well as in the event of withdrawal of consent by the personal data subject to their processing, the Data shall be destroyed, unless:
otherwise provided by a contract to which the personal data subject is a party, beneficiary, or guarantor;
the Company is entitled to process the Data without the consent of the personal data subject on the grounds provided for by the Law or other federal laws;
otherwise provided by another agreement between the Company and the personal data subject.
6.3. The Company is obliged to inform the personal data subject or their representative of the processing of such subject's personal data upon request.
7. Processing of Statistical Data on Visits and Use of the Website
7.1. The Company may use statistical services on the Website, as well as cookies and other similar technologies. These issues are governed by the Policy on Statistical Data and Cookies.
8. Procedure for Responding to Requests/Inquiries from Personal Data Subjects and Their Representatives, Authorized Bodies Regarding Inaccuracy of Personal Data, Unlawfulness of Processing, Withdrawal of Consent, and Access by Personal Data Subjects to Their Data
8.1. Users and Employees, as personal data subjects, have the right to receive information concerning the processing of their Data, including information containing:
confirmation of the fact of processing of Data by the Company;
the legal grounds and purposes of processing Data;
the methods of processing Data used by the Company;
the name and location of the Company, information about persons who have access to Data or to whom Data may be disclosed on the basis of an agreement with the Company or on the basis of federal law;
the processed Data relating to the relevant personal data subject, the source of their receipt, unless a different procedure for providing such data is provided for by federal law;
the periods of processing of Data, including the periods of their storage;
the procedure for the exercise by the personal data subject of the rights provided for by the legislation of the Russian Federation in the field of Data;
information on the cross-border transfer of Data that has been carried out or is intended;
the name of the organization or the surname, first name, patronymic, and address of the person processing Data on behalf of the Company, if processing is or will be entrusted to such organization or person;
other information provided for by the legislation of the Russian Federation in the field of personal data.
To obtain this information, Users and Employees have the right to contact the Company using the contact details specified in Section 8.14 below.
8.2. Personal data subjects have the right to demand that the Company clarify their Data, block or destroy it if the Data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights.
8.3. The above information must be provided to the personal data subject by the Company in an accessible form, and must not contain Data relating to other personal data subjects, except in cases where there are legal grounds for disclosing such Data.
8.4. The information specified in this section shall be communicated to the personal data subject or their representative, and they shall also be given the opportunity to review the relevant Data upon request or within 30 days from the date of receipt of the request from the personal data subject or their representative. The request must contain:
the number of the main identity document of the personal data subject or their representative, information on the date of issue of the specified document and the authority that issued it;
information confirming the participation of the personal data subject in legal relations with the Company, or information otherwise confirming the fact of processing of personal data in the Company, the signature of the personal data subject or their representative. The request may be sent in the form of an electronic document and signed with an electronic signature in accordance with the legislation of the Russian Federation.
8.5. If the information specified in this section, as well as the processed Data, was provided for review to the personal data subject upon their request, the personal data subject has the right to contact the Company again or send a repeated request to obtain the specified information and review such Data no earlier than thirty days after the initial request or submission of the initial request, unless a shorter period is established by federal law, a regulatory legal act adopted in accordance with it, or a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.6. The personal data subject has the right to contact the Company again or send a repeated request to obtain the above information, as well as to review the processed Data before the expiration of the period specified in the previous paragraph, if such information and/or processed Data were not provided to them for review in full following the consideration of the initial request. The repeated request must contain a justification for submitting the repeated request.
8.7. The Company has the right to refuse the personal data subject to fulfill a repeated request that does not meet the conditions established by law. Such refusal must be reasoned.
8.8. The right of the personal data subject to access their Data may be limited in accordance with federal laws, including if the personal data subject's access to their Data violates the rights and legitimate interests of third parties.
8.9. The Company shall report to Roskomnadzor, at the request of this body, the necessary information within thirty days from the date of receipt of such request.
8.10. All incoming requests and inquiries are registered as incoming correspondence and are also recorded in the relevant registers of the Company.
8.11. Requests and inquiries are considered by the Person Responsible for the processing of personal data. If questions arise or it is necessary to clarify the content of the request, the Person Responsible for the processing of personal data contacts the person who sent the request/inquiry using the contact details provided therein.
8.12. The response to the request/inquiry shall be drawn up in the same form in which the corresponding request/inquiry was received (for example, by email or in paper form), unless otherwise expressly provided by the legislation of the Russian Federation or a different request is not contained in the request/inquiry.
8.13. The response to a personal data subject's inquiry may be signed by the Person Responsible for the processing of personal data or by the General Director of the Company. The response to a Roskomnadzor request shall be signed by the General Director of the Company or a person acting on their behalf on the basis of a power of attorney issued on behalf of the Company.
8.14. The request/inquiry shall be sent in any form to the following address:
ICC "New Time"
Postal address: 127254, Moscow, Goncharova Street, Building 9A, Floor/Premises 1/I, Room/Part of Room 6A/6
Email: info@iccnt.ru
Telephone: +7 995 520 17 66
Working hours: Monday through Friday from 10:00 AM to 6:00 PM, excluding public holidays in Russia.
Appendix. Information on the Implemented Requirements for the Protection of Personal Data.
As necessary and taking into account threats relevant to information systems ensuring the functioning of the Website and the processing of Data, the Company implements the following requirements for Data protection or ensures their implementation by persons engaged for Data processing:
organization of a security regime for the premises in which the information system is located, preventing the possibility of uncontrolled entry or presence in these premises of persons who do not have the right of access to these premises;
ensuring the safety of Data media;
approval by the head of the operator of a document defining the list of persons whose access to Data processed in the information system is necessary for them to perform their official (labor) duties;
the use of information security tools that have passed the conformity assessment procedure with the requirements of the legislation of the Russian Federation in the field of information security, if the use of such tools is necessary to neutralize current threats;
appointment of an official (employee) responsible for ensuring the security of personal data in the information system;
ensuring the possibility of access to the contents of the electronic message log exclusively for officials (employees) of the operator or an authorized person who need the information contained in the said log to perform their official duties.
QUICK LINKS
CONTACTS
+7 (991) 756-58-88
127254, Russia, Moscow, Goncharova Street, Building 9A, Office 6A
web@iccnt.ru
All rights reserved. Reprinting and distribution of data from the website in any form is permitted only with the written permission of an authorized representative of the Cooperative.