1.3. We are a “Controller” under the General Data Protection Regulation (the GDPR) and other applicable data protection legislation (Data Protection Law). This means we are responsible for deciding how we use the personal data that we collect about you and, in accordance with the Data Protection Law, we will ensure that the data we hold about you is, at all times used fairly, lawfully, and transparently; collected for limited, specific purposes only; adequate, relevant to and limited to what is necessary for those purposes; kept accurate and up-to-date; not kept for longer than is necessary; held securely.
3. Information Collected
3.1. The data collected and processed by the Operator are not personal data and cannot be used for identification of any particular person. We may collect only Technical anonymous data from you while you‘re surfing our website.
3.2. When you visit the Site, we automatically collect certain information regarding technical devices, technical interaction with the Site. This data includes:
3.2.1. The host IP address, Mac Address and other device identifiers;
3.2.2. The type of device by which the user has logged in to the site;
3.2.3. The browser type, its version and language;
3.2.4. Time zone settings;
3.2.5. Date and time of visiting;
3.2.6. The type of operating system and its version;
3.2.7. The unique user IDs that are assigned automatically;
3.2.8. Data on the location (geographic position);
3.2.9. The Internet provider.
3.2.10. Users’ navigation (the path) on the website (the Users' order of opened pages of the Website, length of visit to certain pages);
3.2.11. Users’ clickstream to, through and from our website (including date and time);
3.2.12. The user’s activity on the site, page interaction information (such as scrolling, clicks, and mouse-overs);
3.2.13. The number and frequency of the site visits;
3.2.15. Domain name of social media network that provided you by an advertisement link to our website (https://vk.com or https://facebook.com).
3.2.16. Number of users that opened our website by advertisement link that had been provided by https://vk.com.
3.2.17. Number of users that opened our website by advertisement link had been provided by https://facebook.com.
4. How we collect your personal data?
4.1. We collect data stated in paragraphs 3.2.1-3.2.14 using Google Analytics and Yandex.Metrika.
4.3. If you don’t want to give us your consent to process your anonymous data stated in in paragraphs 3.2.1-3.2.14 – please, leave our Website immediately.
5. Purposes of data processing
5.1. We may process your data stated in paragraphs 3.2.1-3.2.14 in order to operate and administer our Website including as necessary for testing, analysis, maintenance, support, reporting and hosting of data. Therefore we use this data on the basis that it is necessary for our legitimate interests of operating our Website, and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site).
5.2. We may process your data stated in articles 3.15-3.17 to advertise our products by social media networks to those persons who interested in products located on our website, to count key performance indicators (KPI) of our products’ social media marketing and/or to count whether advertisement of our products is effective on https://vk.com and https://facebook.com separately.
6. How can we use your data?
6.1. We use information stated in paragraphs 3.2.1-3.2.14 on an anonymous basis and will never use it to identify any particular user. We won't be able to link this data to any other data that we hold about you and the purpose of collecting this data is to perform analysis and to help us identify people flows around our stores to maximize the efficiency of our store design.
6.2. We are not in a position to identify you as a natural person. According to Article 11(2) of the GDPR we need to inform you that Articles 15 to 20 of the GDPR shall not apply except where you, for the purpose of exercising your rights under those articles, provide us additional information enabling your identification.
6.3. In the case stated in 6.2 if you provide us additional information enabling your identification we will delete it immediately after closing the discussion with you. All correspondence received by us from you is classified as confidential information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.
6.4. The Operator does not collect and/or process any information about the Users’ bank cards or bank accounts.
7. What are cookies?
7.1. Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. They are often used as a mechanism for websites to remember useful information, such as your login details, and can contribute to ease of use when navigating a website. Our cookies cannot identify you personally.
7.2. Cookies can remain on your device for different periods of time. Some cookies are ‘session cookies’, meaning that they exist only while your website browser is open and are deleted automatically when you close your browser. Other cookies are semi-permanent cookies, meaning they survive after your browser is closed and can be used by websites to recognize your device when you later re-open your browser and browse the internet again.
7.3. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org/.
8.1. Analytical cookies - such type of cookies allows us to count the number of users of our Website and see how such users navigate through it. We use it to improve our Website work and to build an anonymous statistics about users’ preferences on our Website and to count in what type of product the masses of anonymous users prefer. Served by Google (google.com/analytics) and Yandex (https://yandex.com/legal/metrica_eea_termsofuse/).
9. How do I reject cookies?
9.1. At any time, you can prevent cookies from being set on your browser. For instructions on how to block, delete or disable any cookies, please consult your browser's 'Help' or 'Support' section. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our website.
9.2. Please consult the following links for information on cookie management and blocking according to your browser:
9.2.1. Explorer: http://windows.microsoft.com/en-gb/internet-explorer/delete-manage- cookies#ie=ie-11.
9.2.2. Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website- preferences
9.2.3. Chrome: https://support.google.com/chrome/answer/95647?hl=en
9.2.4. Safari: https://support.apple.com/kb/PH19214?locale=en_GB
9.3. You can find general information and opt-out resources at youronlinechoices.eu.
9.4. You may refuse the storage of cookies by selecting the appropriate settings on your browser. You may also prevent the collection of the data referring to you that are generated by the cookie (including your IP address) in relation to the use of the Website and the subsequent transfer to Google and the processing of these data by Google by downloading and installing the browser plug-in available at the following link https://tools.google.com/dlpage/gaoptout/. In this case, an opt-out cookie is stored which prevents the future collection of your data when you visit the website.
10. "We use the information we collect from you for the purposes of:
a. Providing you with an appropriate reply to your request;
b. Protecting the rights and interests of Operator and others.
10.1. We process your data for the purposes identified above, as necessary, (1) for the legitimate interests of us and other third parties, including maintaining and administrating the Services; (2) to comply with our legal obligations;
10.2. "Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defence or exercise of legal claims. We will not delete personal information if it is relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law."
11. Data sharing
11.1. "We may share your personal information with companies, organisations and individuals inside and outside of the Operator where one of the following circumstances applies:
c. to other companies in our group, for administrative and management, subject to us taking reasonable measures to ensure that your information is kept secure at all times;
d. to trusted third parties businesses, or persons who perform services and process your personal information for us for the purposes listed above, based on our instructions, subject to us taking reasonable measures to ensure that your information is kept secure at all times;
e. to companies, organisations or individuals outside of Operator if we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to: o meet any applicable law, regulation, legal process or enforceable governmental request; o detect, prevent or otherwise address fraud, security or technical issues; or o protect against harm to the rights, property or safety of the Operator, our customers or the public, as required or permitted by law."
11.2. We may share your data other our affiliates. Sometimes we may also need to share your data with a third party in order to provide our services to you or to administer the Site, for example if you choose to share your data across other social media platforms.
12. International Transfers
12.1. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA). Such transfers take place to enable us to provide you with our products and services, for customer relationship management purposes.
12.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction or same personal information protection standards. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.
12.3. We do not generally or routinely transfer personal data outside of the EU but some of the organizations to which we may disclose your non-personal data may be situated outside of the EU, including but not limited to Russian Federation.
12.4. If we do transfer your data outside of the EU, we will ensure that your data is protected to a similar degree in accordance with General Data Protection Regulation and Data Protection Legislation. We may do this by approving one of the specific safeguards approved by the European Commission is in place. You can find further information about these safeguards at https://ec.europa.eu/info/law/law-topic/data-protection_en.
13. Links to external websites
13.1. Our Website contains links to other websites that are not owned or controlled by us.
14. Your Rights
14.1. The users have the right to control the confidentiality of the data processed through the Site and contact the Operator with requirements, proposals, other messages by using the details specified in this Policy.
14.2. "You have the following rights, in certain circumstances, in relation to your personal information:
a. Right to access your personal information.
b.Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
c. Right to restrict the use of your personal information.
d. Right to request that your personal information is erased.
e. Right to object to processing of your personal information.
f. Right to data portability (in certain specific circumstances).
g. Right not to be subject to an automated decision including profiling which produces legal effects concerning him or her or similarly significantly affects him or her.
h. Right to lodge a complaint with a supervisory authority. "
14.3. If you would like to exercise these rights, please contact Support Service at email@example.com. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you.
14.4. We are not in a position to identify you as a natural person. According to Article 11(2) of the GDPR we need to inform you that article 15 (“a” to “f”) shall not apply except where the data subject, for the purpose of exercising his or her rights provides additional information enabling his or her identification.
15. Security Measures
15.1. We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.
15.2. The Operator does not provide the delivery or sale of the goods depicted on the Website. All the content depicted on the Website is provided for informational purposes only. The user expresses the will to transit to the web pages of any off-site online stores and sites by clicking the button with link, for example, “buy now”.
16. Changes to this Policy
17. Contact Us
17.2. All correspondence received by us from you is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.