(Non-Disclosure Agreement)


1. General Provisions


This Personal Data Processing Policy has been developed pursuant to the requirements of Federal Law No. 152-FZ dated 27 July 2006 ‘On Personal Data’ and stipulates the personal data processing procedures and measures to ensure personal data protection effected by «Sputnik Partners» Limited Liability Company, (INN (Taxpayer Identification Number) 7839110984, OGRN (Principal State Registration Number) 1187847380434, Legal address: Russia, St. Petersburg, 199-201 Obvodny Canal Embankment, litera K, premises 3N, office 1)  (hereinafter, the Operator).
1.1. The Operator believes that its primary goal and prerequisite for conducting its business is to respect the human and civil rights and freedoms while processing personal data, including the personal and family privacy rights.
1.2. This Personal Data Processing Policy of the Operator (hereinafter, the Policy) applies to any and all information obtained by the Operator with regard to the Users of the Application available at the following website:


2. Policy Terms and Definitions


2.1. Automatic processing of personal data is the processing of personal data by means of computer technology;
2.2. Blocking of personal data is the temporary suspension of personal data processing (except where processing is required to correct or update the personal data);
2.3. Application is the set of graphics and information materials, as well as the software and databases ensuring their accessibility on the Internet at the following address:
2.4. Personal data information system is the set of personal data stored in databases and the information technologies, hardware and software enabling their processing;
2.5. Personal data anonymisation means actions which render it impossible to identify personal data as relating to a specific User or any other personal data subject without using additional information.
2.6. Personal data processing is any action/operation or sequence of actions/operations performed with or without automation aids and involving personal data, including collection, recording, systematisation, accumulation, storage, specification (update, revision), extraction, use, transfer (circulation, provision, access), anonymisation, blocking, removal, and obliteration of personal data;
2.7. Operator is a state or municipal authority, legal entity or individual which, independently or together with other parties, enables and/or performs personal data processing, as well as determines the purposes of personal data processing, the scope of personal data to be processed, and the actions/operations with the personal data;
2.8. Personal data is any information that directly or indirectly relates to an identified or identifiable User of the Application.
2.9. User is any user that has downloaded and installed the Application;
2.10. Provision of personal data means actions aimed at disclosing personal data to a certain party or group of parties;
2.11. Circulation of personal data means any actions aimed at disclosing personal data to an indefinite number of unspecified parties (transfer of personal data) or at making personal data available to the general public, including the publishing of personal data in the mass media, posting on the information and telecommunications networks, or granting access to personal data in any other way;
2.12. Cross-border transfer of personal data is the transfer of personal data to a foreign state authority, legal entity, or individual in a foreign jurisdiction.
2.13. Obliteration of personal data means any actions resulting in the irrevocable obliteration of personal data without the option to subsequently restore the contents of personal data in the personal data information system and/or destruction of the physical media on which personal data are stored.


3. Personal Data of the User to Be Processed


3.1. Full name;
3.2. Email address;
3.3. Phone numbers;
3.4. Year, month, date and place of birth;
3.5. Photographs;
3.6. Actual place of residence and registered address;
3.7. Education, profession, occupation, qualification; details of the academic certificates;
3.8. Gender;
3.9. The Application will also collect and process anonymised User data (including cookies) using web analytics services, as well as the following User data: location; operating system type and version; browser type and version; device type and screen resolution; User referrer, website or advertisement by which the User was referred to the current site; operating system and browser language; pages visited and buttons clicked by the User; IP address.
3.10. The data listed above shall hereinafter be collectively referred to as the Personal Data.


4. Personal Data Processing Purposes


4.1. The purpose of processing the User’s personal data is to inform the User by sending emails; to enter into, perform, and terminate civil law contracts; and to enable the User’s access to the services, information and/or materials stored on the website. 
4.2. The Operator is also entitled to notify the User of new products and services, special offers and various events. The User may at any time unsubscribe from such notifications by sending to the Operator’s email address an email with the subject ‘Unsubscribe from notifications about new products and services and special offers.’
4.3. Anonymised User data collected with web analytics services are intended to gather information about the Users’ activities on the website and improve overall website quality and content.


5. Legal Framework for Personal Data Processing


5.1. The Operator shall process the User’s personal data only if they are filled in and/or sent by the User on his or her own behalf through special forms contained in the Application. By filling out the relevant forms and/or sending his or her personal data to the Operator, the User consents to this Policy.
5.2. The Operator shall process anonymised User data if this is allowed by the User’s browser configurations (with cookies and JavaScript enabled).

6. Procedure for Collection, Storage, Transfer, and Other Personal Data Processing Actions


The protection of personal data processed by the Operator shall be ensured by legal, organisational and technical measures required to fully comply with the applicable personal data protection laws.
6.1. The Operator shall ensure the integrity of personal data and take every possible measure to prevent unauthorised access to personal data.
6.2. The User’s personal data shall in no case and under no circumstances be transferred to third parties, unless otherwise required by applicable legislation.
6.3. In case of any inaccuracies identified in the personal data, the User may update them personally by sending to the Operator’s email address a notice with the subject ‘Personal Data Update.’
6.4. Personal data processing period shall be indefinite. The User may at any time withdraw his or her consent to personal data processing by sending to the Operator’s email address a notice with the subject ‘Withdrawal of the Consent to Personal Data Processing.’


7. Cross-Border Transfer of Personal Data


7.1. Prior to any cross-border transfer of the personal data, the Operator shall make sure that the relevant foreign jurisdiction has in place appropriate measures to efficiently protect the rights of personal data subjects.
7.2. Cross-border transfer of personal data to any jurisdictions that do not comply with the above requirements may only be effected upon written consent of the personal data subject to such cross-border transfer of his or her personal data and/or by way of performance of a contract to which the personal data subject is a party.

8. Miscellaneous


8.1. The User may request clarifications with regard to any issues related to the processing of his or her personal data by sending a relevant enquiry to the Operator’s email address
8.2. This document shall reflect any and all amendments to the Operator’s personal data processing Policy. The Policy shall remain in force indefinitely until replaced by a newer version.
8.3. The version of the Policy currently in effect shall be freely available on the Internet at