Provisions

about privacy policy

Closed Joint Stock Company "Tract"

I. General Provisions

This Privacy Policy Provision (hereinafter referred to as “the Provision”) is an official document of Tract, CJSC located at: 23 Kronverskaya Street, Saint Petersburg, Russia, 197101 (hereinafter referred to as “the Company”) and defines the procedure for processing and protecting the data on the private individuals (hereinafter referred to as “the Users”) using the features, information, services, programs (including the loyalty programs) hosted at domain names www.digispot.ru and www.tract.ru (hereinafter referred to as “the Website”).

Confidentiality compliance is important for the Company, since the Privacy Policy is aimed at protection of the rights and freedoms of a person and a citizen when processing their personal data, including the protection of privacy rights against unauthorized access and disclosure.

The company has developed the Privacy Policy, which describes the way personal data is processed — any personal data handling actions (operations) or a set of actions (operations) that engage automation tools or not, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), de-identification, blocking, deletion, destruction of personal data.

This Privacy Policy regulates any type of handling of the personal data (any information that allows for identification of an individual, or any other data associated therewith) that concerns private individuals who are consumers of Company’s products or services.

This Policy covers procession of any personal data obtained by any means both active and passive, through the Internet or without the use thereof, from any persons worldwide.

II. Personal Data Collection

Personal data is processed in order to reach fulfilment of Operator’s obligations vis-à-vis the Users regarding the use of the Website and its features.

Users’ personal data is processed upon the consent from a personal data subject to their personal data processing.

Personal data imply any information that is associated with a definite private individual (personal data subject) and may be used to identify a definite individual or get in contact therewith.

The Company may request your personal data at any time when you get in touch with the Company. The Company may use such data in accordance with this Privacy Policy. It may also combine this information with other information in order to provide and improve its products, services, informational content and communications.

The Company may collect various data including:

— name and surname

— mailing address

— telephone number

— e-mail address

employment information, invoicing details and position

Personal data may also include the data additionally provided by the Users upon Operator’s request to ensure compliance of Operator’s obligations vis-à-vis the Users under the service provision agreement.

III. Storage and Use of Personal Data

Users’ personal data is stored in soft copies only and processed using automated systems.

The personal data collected by us allows us to send notifications about new products, special offers and various events to you. They also help us improve our services, content and communications. If you are not willing to be in our email list, you may opt out of the email list by using the specified feedback details to inform us or by changing the settings of your profile online.

The Company may also use your personal data for its internal purposes such as auditing, data analysis and various researches performed for improvement of Company’s products and services, and customer communication.

If you take part in giveaways, competitions or similar stimulating events, the Company bears the right to use the personal data provided by you to manage such programs.

The Company also collects personal data that is not private – the data that does not suggest direct linking to a definite person. We may collect, use, convey and disclose such non-private information for any purposes. Examples of non-personal data collected by us and the ways we use it are given below:

We may collect such personal information as data on your occupation, language, postal code, unique ID of your device, your location and time zone where some product is used to improve our knowledge of customer behavior as well as our products, services and communications.

The Company may also collect personal data / information about what the user is interested in on our website when using our other products and services. Such personal data / information is collected and used to help us provide more useful information to our customers, and to understand what elements of our website, products and services are the most interesting. For the purposes of this Privacy Policy, the aggregate data is treated as non-private data / information.

IV. Disclosure of Personal Data

Users’ personal data is not disclosed to any third persons except for the cases provided for by these Rules. Users’ personal data is processed with no time limitation, through any legal procedure including in the personal data systems using automation means or not using any of these.

Users’ personal data may be conveyed upon request from the state regulatory authorities of the Russian Federation only based on the reasons and according to the procedure established by the legislation of the Russian Federation.

Disclosure of the Data to Third Persons

In some cases, the Company may provide some personal information and data to its strategic partners that cooperate with the Company to provide products and services, or to those providing assistance to the Company in selling the products and services to customers. We disclose the minimum amount of your personal data to third parties required to provide a specific service or implement a specific transaction.

We will request your consent to processing of your personal data in order to use your personal data for any other purposes.

VI. Personal Data Protection

The Company takes safety precautions including legal, organizational, administrative, technical and physical ones to protect your personal data in accordance with Art. 19 of Federal Law No. 152-FZ “On Personal Data” dated 27.07.2006 in order to protect personal data of users from illegal or accidental access, destruction, amendment, blocking, copying, distribution and from other unlawful acts of third parties.

ThirdParty Websites and Services

Company’s websites, products, applications and services may contain links to some third-party websites, products and services. Our products and services may also use or offer some third-party products and services. The personal data and information collected by the third parties that may include such data as location or contact details are subject to such third-party privacy rules. You are recommended to look through such third-party privacy rules.

PrivacyAssociated Questions

If you have any questions regarding Company’s Privacy Policy or data procession performed by the Company, contact us using the feedback details.

Miscellaneous

In any other issues not provided for in the Privacy Policy, the Company shall be guided by the rules and regulations of Federal Law No. 152-FZ “On Personal Data” dated 27.07.2006.

Any Company’s website visitor providing their personal data and information hereby agrees to the provisions of the Privacy Policy.

The Company reserves the right to make any changes to the Policy at any time at its sole discretion to ensure further improvement of the system for protection of the personal data provided by the Users from any unauthorized access with no User’s consent.

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