This Privacy Policy with regard to processing and protection of personal data determines the position of ARCTIC7 Limited Liability Company (hereinafter referred to as ARCTIC7 LLC, the Company) in processing and protection of personal data, observing the rights and freedoms of each individual and in particular the right to privacy, personal and family secrets.

1. TERMINOLOGY

1.1 The following terms are used in this Privacy Policy:

1.1.1 Confidentiality of Personal Data - a binding requirement of the Company or any other person having access to Personal Data to prevent its distribution without the consent of the subject of Personal Data or availability of any other legal basis.

1.1.2 Processing of personal data - any action (operation) or set of actions (operations), performed with or without the use of computer equipment with personal data, including collection, recording, systematization, accumulation, storage, detailing (update, modification), extraction, use, transfer (distribution, provision, access, including cross-border transfer), depersonalization, blocking, deletion, destruction of personal data.

1.1.3 Personal data - any information relating directly or indirectly to a defined or identifiable individual (personal data subject).

1.1.4 Website User (the User) - a person who accesses the Website via the Internet and uses the Website.

1.1.5. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign country to a foreign authority, foreign individual or foreign legal entity.

1.1.6. Cookies - a minor fragment of data sent by a web server and stored on the user's computer, which the web client or web browser sends to the web server each time in HTTP-request when trying to open a page of the corresponding website.

1.1.7. IP address - a unique network address of a host in an IP-based computer network.

2. GENERAL PROVISIONS

2.1 Understanding the importance and value of Personal Data, and taking care of respect for the constitutional rights of citizens of the Russian Federation and citizens of other states, the Company provides reliable protection of Personal Data.

2.2. Being a user of the official website of ARCTIC7 LLC at: www.arctic7.com (hereinafter referred to as the Website), the User provides the Company with their Personal Data and gives full and unconditional consent to its processing, including cross-border transfer, exclusively in line with this Privacy Policy.

2.3 Personal data is provided by users on a voluntary basis and may be modified (updated, supplemented, deleted) at their request.

2.4 In case of disagreement with the terms of this Privacy Policy, the User must stop using the Website.

2.5 This Privacy Policy is only applicable to the Company's Website. The Company does not control and is not responsible for third parties' websites, to which the User can follow via the links available on the Website.

2.6 The Company does not verify reliability of personal data provided by the Website User.

2.7 Processing and security of Data in the Company is carried out in accordance with the requirements of the legislation of the Russian Federation, including Federal Law No. 261-ФЗ On Personal Data dated 27.07.2011 (hereinafter referred to as the Federal Law)

3. SUBJECT OF PRIVACY POLICY

3.1 The present Privacy Policy determines the obligations of the Company not to disclose and ensure the protection of confidentiality of personal data, which the User provides upon request by the Company, while using the Website.

3.2 Personal data which is allowed for processing under this Privacy Policy is provided by the User by filling out the forms on the Website, and comprises the following information:

3.2.1. Surname, name, patronymic of the User;

3.2.2. Contact phone number of the User; 

3.2.3. E-mail address (e-mail);

3.2.4. Location of the User; 

3.3 The Website protects data, which is automatically transferred in the process of viewing ads and when visiting pages on which the system's statistical script (pixel) is installed:

3.3.1. IP address;

3.3.2. information from cookies;

3.3.3. information about your browser (or other program that accesses advertising display);

3.3.4. access time;

3.3.5. address of the page on which the ad unit is located;

3.3.6. referrer (address of the previous page).

3.4 The Website collects statistics about the IP addresses of its visitors. This information is used to identify and solve technical issues.

3.5 Any other personal information not mentioned above (used browsers, operating systems, etc.) shall be stored securely and shall not be disclosed, except as required by law.

4. PRINCIPLES OF PROCESSING AND PURPOSES OF PERSONAL DATA PROCESSING

4.1. Principles of Processing of the User’s Personal Data:

4.1.1. Processing of Personal Data shall be performed on a lawful and fair basis;

4.1.2. Processing of Personal Data should be limited to achieving specific, predetermined goals, in accordance with clause 4.2 of this Policy;

4.1.3. Processing of Personal Data that is incompatible with the purposes of Personal Data collection is not allowed;

4.1.4. The content and volume of processed Personal Data shall be consistent with the stated processing purposes;

4.1.5. Combining databases containing Data, which is being processed for purposes incompatible with each other, is not allowed;

4.1.6. Storage of Personal Data must be in a form enabling identification of the subject of Personal Data;

4.1.7. Personal Data may be processed only for purposes directly related to the Company's activities, in particular, to provide the stated services and activities specified in the Company's Articles of Association, in the Unified State Register of Legal Entities.

4.2. Processing of Personal Data shall be performed in accordance with the requirements of the Federal Law On Personal Data, this Policy and may be performed for the purposes of:

4.2.1. Establishment of communication with the User, including sending notifications, requests regarding the use of the Website, the provision of services, processing of requests and applications from the User;

4.2.2. Analysis of quality of the Service provided by the Company and improvement of the Company's customer service quality;

4.2.3. Provision of effective customer and technical support to the User in the event any issues arise related to the use of the Website;

4.2.4. Provision to the User, with their consent, of product updates, special offers, pricing information, newsletters and other information on behalf of the Company;

4.2.5. Performance of advertising with the User's consent.

5. METHODS AND TERMS OF PERSONAL INFORMATION PROCESSING

5.1 Processing of personal data of the User shall be performed indefinitely, by any legal means, including in the information systems of personal data with or without the use of computer equipment.

5.2 The Company shall collect, record, systematize, accumulate, store, detail (update, modify), extract, use, transfer (distribute, provide, access), depersonalize, block, delete and destroy Personal Data, in accordance with this Privacy Policy and the Regulations on Processing of Personal Data of Arctic7 LLC.

5.3 If the subject of Personal Data withdraws consent to the processing of their Personal Data, the Company shall cease its processing or ensure that such processing is ceased (if the processing of Personal Data is performed by another person acting on behalf of the Company) within a period not exceeding 30 (Thirty) days from the date of receipt of the said withdrawal, unless otherwise provided for by law.

5.4 The Company shall notify the subject of Personal Data about the destruction of Personal Data.

5.5 The User agrees that the Company may transfer Personal Data to third parties solely for the purpose of providing the services requested by the User.

5.6 The User’s Personal Data may be transferred to the authorized public authorities of the Russian Federation only on the grounds and in the manner prescribed by the legislation of the Russian Federation.

5.7 The Company shall take the necessary administrative and technical measures to protect the User's Personal Data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions of third parties.

5.8 The Company along with the User shall take all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's Personal Data.

6. RIGHTS AND OBLIGATIONS OF THE PARTIES

6.1 The User is entitled to:

6.1.1. Receive information relating to the processing of their Personal Data, including:

• confirmation of the fact of processing of their Personal Data;
• legal basis and purpose of processing of Personal Data;
• applicable methods of processing of Personal Data;
• information about persons who have access to the User’s Personal Data or to whom the User’s Personal Data may be disclosed on the basis of an agreement with the Company or on the basis of the federal law;
• list of processed Personal Data pertaining to the relevant subject of Personal Data, the source of its obtaining, unless another procedure for providing such data is provided for by federal law;
• terms of processing of Personal Data, including terms of its storage;
• procedure for exercising the rights provided for by the Federal Law On Personal Data by the subject of Personal Data
• information on cross-border transfer of personal data that has taken place or is expected to take place;
• name (surname, name, patronymic) and address of the person processing their Personal Data on behalf of the Company, if the processing is assigned or will be assigned to such person 
• other information required by the Federal Law On Personal Data or other federal laws.

6.1.2 Demand that the Company detail, block or destroy their Personal Data, if such data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing;

6.1.3. Withdraw their consent to the processing of Personal Data at any time;

6.1.4. Demand the seizure of unlawful actions of the Company in relation to their Personal Data;

6.1.5. Appeal against actions or inactions of the Company if the User believes that the Company is processing their Personal Data in violation of the requirements of the Law or otherwise violates their rights and freedoms;

6.1.6. Protection of their rights and legitimate interests, including compensation for damages and/or moral harm through judicial procedures.

6.2 The Company shall:

6.2.1. Provide to the subject of Personal Data upon their request information relating to the processing of their Personal Data, or lawfully provide a waiver within 30 (Thirty) days from the date of receipt of the request of the subject of Personal Data or their representative;

6.2.2 Before processing Personal Data, provide to the subject of Personal Data the following information, except as required by Part 3, Article 18 of the Federal Law:

• name or surname, name, patronymic and address of the Company or its representative;
• purpose of Personal Data processing and legal basis therefor;
• intended users of Personal Data;
• statutory rights of the subjects of Personal Data;
• source of obtaining Personal Data.

6.2.3 Use the information obtained solely for the purposes specified in clause 4.2 of this Privacy Policy.

6.2.4. Ensure that private information is kept confidential, not sell, exchange, publish, or disclose in any other possible ways the transferred User’s Personal Data, except for clauses 5.5, 5.6 of this Privacy Policy.

6.2.5 Take precautions to protect confidentiality of the User’s Personal Data, according to the procedure generally used for the protection of such information in the existing business practice.

6.2.6. Block Personal Information pertaining to the respective User from the moment of application or request of the User or their legal representative, or authorized body for the protection of the rights of subjects of Personal Data for the period of verification, if it discovers inaccurate Personal Data or unlawful acts.

6.2.7. Terminate the processing of Personal Data or ensure its termination and destroy Personal Data or ensure its destruction if the subject of Personal Data withdraws consent to the processing of their Personal Data, if the Company is not entitled to carry out this processing without the consent of the subject of Personal Data.

7. LIABILITY OF THE PARTIES

7.1 The Company, failing to fulfil its obligations, shall be liable for losses incurred by the User in connection with the misuse of their Personal Data, in accordance with the legislation of the Russian Federation.

7.2 In the event of loss or disclosure of confidential information, the Company shall not be liable if such confidential information:

7.2.1. Became public knowledge before its loss or disclosure.

7.2.2. Was disclosed with the User's consent.

8. DISPUTE RESOLUTION

8.1 Before filing a lawsuit arising out of the relations between the User and the Company, a claim (written proposition to voluntarily settlement of the dispute) shall be submitted.

8.2 Within ten (10) calendar days after receipt of the claim, the recipient of the claim shall notify the claimant in writing of the results of consideration of the claim.

8.3 In case of failure to reach a settlement, the dispute will be transferred for consideration in a judicial authority in accordance with the current legislation of the Russian Federation.

8.4 The current legislation of the Russian Federation applies to this Privacy Policy and the relationship between the User and the Company.

9. FINAL PROVISIONS

9.1. The Company is entitled to introduce amendments in this Privacy Policy without the consent of the User.

9.2 A new Privacy Policy becomes effective upon its posting on the Website, unless otherwise provided for by the new Privacy Policy edition.

9.3 This Policy constitutes a local regulatory document of the Company.

9.4 This Policy shall be publicly available. Public accessibility of this Policy is ensured by publishing it on the Company's website at: www.arctic7.com

9.5 This Policy may be revised in any of the following cases:

9.5.1. In case of changes in the legislation of the Russian Federation in the field of processing and protection of personal data;

9.5.2. In cases of orders from competent state authorities to eliminate inconsistencies affecting the scope of the Policy;

9.5.3. By the decision of the Company's management;

9.5.4. In case of changes in the purposes and terms of Personal Data processing; 

9.5.5. In case of changes in the administrative structure, the structure of information and/or telecommunication systems (or introduction of new ones);

9.5.6. Upon application of new technologies for processing and protection of Personal Data (including transfer, storage);

9.5.7. In case of a need to change the process of Personal Data processing related to the Company's activities.

9.6 In case of failure to comply with the provisions of this Policy, the Company and its employees shall be liable in accordance with the current legislation of the Russian Federation. Supervision of compliance with this Policy is carried out by the persons responsible for arranging the processing and security of Personal Data.

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‍Saint Petersburg 

2022