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Privacy Policy

Last updated: February 14, 2025

GENERAL PROVISIONS

This Privacy Policy (hereinafter referred to as the Policy) defines the basic principles, goals, terms, and methods of personal data processing LLC «RUBRUKS» (OGRN 1195081032431, INN 5047226242, legal address/registration address: 109428, Moscow, 1st Institutsky proezd, bld. 3, str. 5 (hereinafter referred to as the Operator).

1.2. This Policy has been developed in accordance with the requirements of Paragraph 2, Part 1, Article 18.1 of the Federal Law of July 27, 2006 No. 152-FZ «On Personal Data» (hereinafter referred to as the Personal Data Law) taking into account the requirements of the Personal Data Law and other normative legal acts of the Russian Federation in the field of personal data.

1.3. This Policy applies to all operations carried out by the Operator with personal data, with or without the use of automation tools. The Operator processes the personal data of the personal data subject only if it is filled in and/or sent by the personal data subject independently through the forms on the website rubruks.ru and its subdomains (hereinafter - the Site). By filling in the relevant forms and/or sending their personal data to the Operator, the personal data subject expresses their consent to this Policy.

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.

1.5. This Policy is subject to update on the initiative of the Operator, as well as in case of changes in the legislation of the Russian Federation on personal data.

2. BASIC CONCEPTS

2.1. For the purposes of this Policy, the terms below are used with the following meaning:

Personal data is any information that relates, directly or indirectly, to an identified or identifiable natural person (data subject).

Biometric personal data are information that characterizes the physiological and biological characteristics of a person, based on which their identity can be established.

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

Automated processing of personal data is the processing of personal data using computer facilities.

Dissemination of personal data refers to actions aimed at disclosing personal data to an indefinite number of persons.

Disclosure of personal data is an action aimed at disclosing personal data to a specific person or a specific group of persons.

Blocking of personal data is the temporary cessation of the processing of personal data (except in cases where processing is necessary to clarify personal data).

Destruction of personal data refers to actions that make it impossible to restore the content of personal data in a personal data information system and/or result in the destruction of the material carriers of personal data.

Anonymization of personal data is the process of taking actions that make it impossible, without additional information, to determine that personal data belongs to a specific data subject.

Personal Data Subject, Subject — an individual who can be directly or indirectly identified using personal data. Consent to the processing of personal data, Consent — a written or digital document that confirms the Subject's voluntary decision to transfer personal data to the Operator within the scope, on the terms, and for the purposes defined by this Policy and agreements concluded between the Subject and the Operator.

3. PRINCIPLES AND GOALS OF PERSONAL DATA PROCESSING

3.1. The Operator processes personal data taking into account the need to ensure the protection of the rights and freedoms of personal data subjects, including the protection of the right to privacy, personal and family life, based on the following principles:

  • processing of personal data is carried out on a legal basis;
  • processing of personal data is limited to achieving specific, predetermined, and legitimate purposes;
  • personal data processing incompatible with the purposes for which personal data was collected is not permitted;
  • The content and volume of personal data processed correspond to the stated purposes of processing. Redundancy of processed data is not permitted.
  • personal data in relation to the stated purposes of their processing;
  • When processing personal data, personal data accuracy, their sufficiency, and, where necessary, their relevance are ensured.
  • in relation to the purposes of personal data processing;
  • Personal data is stored in a form that allows the identification of the data subject, no longer than necessary for the purposes.
  • processing of personal data if the personal data retention period is not established by federal law, contract to which the personal data subject is a party, beneficiary, or guarantor;
  • processed personal data are destroyed or anonymized upon achievement of the processing goals or in case of loss of necessity for achieving these goals, unless otherwise provided by federal law.

3.2. Processing of personal data by the Operator is carried out for the following purposes:

  • identification of the Subject for the purpose of concluding any agreements with the Operator and their further execution;
  • The Operator conducting promotions, surveys, interviews, tests, and research on the Website;
  • establishing contact with the Feedback Subject, including, but not limited to: sending out mailings, notifications via SMS, emails, oral and written inquiries, processing inquiries and applications from the Subject;
  • confirmation of the accuracy and completeness of personal data provided by the Subject;
  • statistical and other research and/or analytical purposes, provided that the Subject's personal data is anonymized.

4. VOLUME AND CATEGORIES OF PROCESSED PERSONAL DATA, CATEGORIES OF PERSONAL DATA SUBJECTS

4.1. The Operator may process the personal data of the following Data Subjects:

  • individuals and representatives of counterparties – legal entities;
  • site visitors

4.2. The personal data processed by the Operator include:

  • Surname, first name, patronymic of the personal data subject;
  • mobile phone number;
  • email address;
  • Social media profile link;
  • Search and view history on the Site and its services;
  • Cookies, user location data, user activity data on the Site, user equipment data, session date and time.

4.3. The Operator ensures that the content and volume of processed personal data comply with the stated purposes of processing and, if necessary, takes measures to eliminate their redundancy in relation to the stated purposes of processing.

5. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA

5.1. The Operator processes personal data in the following ways:

  • manual personal data processing;
  • automated processing of personal data with or without their transfer via information and telecommunication networks, including processing using automated database management systems and other software tools;
  • Mixed processing of personal data.

5.2. List of actions performed by the Operator with personal data: collection, systematization, accumulation, storage, clarification (updating, changing), use, anonymization, blocking, destruction within the territory of the Russian Federation in accordance with current legislation
Russian Federation.

5.3. The data subject makes the decision to provide their personal data and gives consent freely, voluntarily, and in their own interest.

5.4. The operator does not process biometric personal data.

5.5. The Operator does not carry out cross-border transfers of personal data.

5.6. The Operator does not process special categories of personal data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, or sex life.

5.7. The processing of personal data may be terminated upon achievement of the personal data processing objectives, expiration of the Consent's validity period or withdrawal of the Consent by the Personal Data Subject, as well as upon discovery of unlawful processing of personal data.

5.8. The retention and processing period for personal data begins from the moment the data is transferred until the processing objectives are achieved. Within 30 days from the date of achieving the personal data processing objective, the operator undertakes to delete the personal data. The data subject may withdraw their Consent to the processing of personal data at any time by sending the Operator a notification via email to the Operator's email address indicated in section 9 of this Policy, marked «Withdrawal of consent to process personal data.».

5.9. The Operator undertakes to cease processing the Subject's personal data within 5 (five) business days from the date of receiving the notification in accordance with clause 5.8 of this Policy.

6. FUNDAMENTAL RIGHTS AND OBLIGATIONS

6.1. The Operator has the right to:

6.1.1. To receive from the Subject reliable information and/or documents containing personal data;

6.1.2. require the Personal Data Subject to promptly clarify the provided personal data.

6.2. The Operator is obligated to:

6.2.1. process personal data in accordance with the current legislation of the Russian Federation;

6.2.2. consider appeals from the Data Subject (or their legal representative) regarding personal data processing and provide motivated responses;

6.2.3. provide the Personal Data Subject (or their legal representative) with free access to their Personal Data;

6.2.4. take measures to clarify, destroy personal data of the personal data subject in connection with his (or his legal representative's) request with lawful and reasonable demands;

6.2.5. To organize the protection of personal data in accordance with the requirements of the legislation of the Russian Federation.

6.3. Personal data subjects have the right to:

6.3.1. to full information about their personal data processed by the Operator;

6.3.2. access to their personal data, including the right to obtain a copy of any record containing their personal data, except as otherwise provided by federal law;

6.3.3. for clarification of their personal data, their blocking or destruction in cases where the personal data are incomplete, outdated, inaccurate, illegally obtained, or not necessary for
stated purpose of processing;

6.3.4. For withdrawal of consent to personal data processing;

6.3.5. to take measures provided for by law to protect their rights;

6.3.6. for the exercise of other rights provided for by the legislation of the Russian Federation.

6.4. Data subjects are obliged to:

provide the Operator with accurate personal data;

6.4.2. provide documents containing personal data to the extent necessary for the purpose of processing;

6.4.3. inform the Operator about the clarification (update, change) of their personal data.

6.5. Persons who have provided the Operator with unreliable information about themselves or information about another Personal Data Subject without the latter's consent shall be liable in accordance with the legislation of the Russian Federation.

7. DISPUTE RESOLUTION PROCEDURE

7.1. All disputes and disagreements that may arise between the Operator and the Subjects regarding issues not resolved in the text of the Policy shall be settled through negotiations.

7.2. The Parties are obliged to observe the pre-trial dispute resolution procedure. Before filing a lawsuit concerning disputes arising from the relationship between the Subject and the Operator, a claim (a written proposal for voluntary dispute settlement) must be submitted. The claim shall be considered within 30 (thirty) calendar days from the date of receipt, unless a different pre-trial settlement procedure is established by the current legislation of the Russian Federation.

7.3. If disputes arising from the Policy are not settled through negotiations, they shall be resolved in a court of general jurisdiction at the Operator's location. The current legislation of the Russian Federation shall apply to this Policy and the relationship between the Subject and the Operator.

8. FINAL PROVISIONS

8.1. The Operator has the right to make changes to this Policy. When making changes, the date of the last update is indicated in the current version. The new version of the Policy comes into force from the moment it is posted on the Website, unless otherwise provided by the new version of the Policy. The current version is always available on the Website.

8.2. The form of Consent for the processing of personal data of Site users (Appendix No. 1 to this Policy) is approved by this Policy, which is placed on the Site in public access at the link: http://rubruks.ru/system/politika/

9. OPERATOR DETAILS

LLC «RUBRUKS»
Address: 109428, Moscow, 1st Institutsky Proyezd, bldg. 3, bldg. 5
OGRN 1195081032431
TIN 5047226242
Email address: info@rubruks.ru