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    Privacy Policy

    The subject of this privacy policy is the relationship between the Operator and the User regarding the processing of information related to the User, including his personal data, upon registration of the User, each access and (or) during the use of the Program and (or) the Site by the User.

    1. Terms and Definitions

    1.1. The following terms and definitions are used in this document:

    1.1.1. Operator – limited liability company “ZAVOD GORELTEKH” (address: St. Petersburg, Revolyutsii Highway, 18, lit. A, pom. 4-N, office 1);

    1.1.2. Personal information – information about the User, including his personal data within the meaning of the legislation of the Russian Federation, as well as electronic data collected during the operation of the Site, the Program and (or) during their use;

    1.1.3. Policy – ​​this privacy policy;

    1.1.4. User – a person who has completed the registration and/or authorization procedure on the Website and who has a Profile. For the purposes of this Policy, a User also means a person who has not completed the registration procedure but who accesses the Website, the Program, and/or uses the Website and/or the Program;

    1.1.5. Program – computer program(s), including the Operator’s mobile applications, access to which is provided through the registration procedure and/or authorization on the Website or in the Program;

    1.1.7. Profile – a subsection of the Site or Program where information about the User is located;

    1.1.8. Website – the Operator’s Internet resource, access to which is provided via the Internet information and telecommunications network via the domain name exd.ru and/or via the network address https://exd.ru/;

    1.1.9. Cookies are a fragment of data that is received and processed by the device that the User uses to access the Program and the Website.

    1.2. Other terms used in this Policy and not reflected in this section shall be interpreted in accordance with the concepts provided by federal laws and other regulatory legal acts of the Russian Federation, or in accordance with the meaning implied by the text of this Policy. In the event of any disagreement regarding the interpretation of a term and/or concept used in this Policy, the interpretation determined by the Operator will apply.

    2. General provisions

    2.1. Relationships related to the processing of Personal Information during the User's registration, each access and/or during the User's use of the Program and the Website are governed by the legislation of the Russian Federation, as well as this Policy.

    2.2. Upon registration, each access, and/or use of the Program or Website, the User agrees to this Policy. If the User disagrees with the terms of this Policy, they must refrain from registering or using the Program or Website.

    2.3. Registration and/or authorization on the Site and/or in the Program, including through the use of the Site, as well as the use of the Program and the Site, means the User's unconditional consent to this Policy and the terms and conditions for processing Personal Information specified therein.
    Registration and/or authorization on the Site and/or in the Program, as well as the use of the Program and the Site are the right, and not the obligation, of the User.

    2.4. By registering and/or authorizing on the Site and/or in the Program, as well as by using the Program, the Site User gives the Operator consent to the processing of Personal Information in accordance with this Policy.

    2.5. The Program and Website may contain links to other internet resources that are not managed by the Operator. Third-party internet resources may have separate and independent privacy policies. This Policy applies only to the Program and Website and does not apply to third-party internet resources that the User may access via links available in the Program or on the Website.

    3. Purpose of processing Personal Information

    3.1. Personal information is processed for the purposes of identifying the User; determining the User's location; providing the User with access to the functionality of the Program and the Website, including access to the Profile and other sections of the Program and the Website; providing information about the Operator's services and products, information about the Operator; establishing feedback with the User, including sending notifications, requests, processing requests and applications from the User; other information interaction between the Operator and the User; fulfillment of the Operator's obligations to the User; data analytics; conducting statistical and other studies of the User's interaction with the Program, the Website, the Operator; identifying security threats to the Program, the Website, the User, the Operator and (or) third parties; for other purposes that may be provided for by the agreement with the User, as well as the legislation of the Russian Federation.

    4. Composition of Personal Information

    4.1. Personal information processed by the Operator includes:

    4.1.1. Data about the User provided by him/her to create a Profile during registration, as well as data provided by the User when changing the Profile, such as last name, first name, patronymic, date of birth, information about place of work, information about position, telephone number, email address;

    4.1.2. Data about the User, additionally provided by him at the request of the Operator for the purpose of the Operator fulfilling its obligations to the User and (or) fulfilling the Operator’s duties established by the legislation of the Russian Federation;

    4.1.3. Electronic data that is automatically transmitted by the User's device to the Program, the Site during their use, such as HTTP headers, IP address, cookies, web beacons (pixel tags), browser ID data, information about hardware and software, as well as other data about technical means (devices) and their technological interaction with the Program, the Site;

    4.1.4. Data obtained as a result of the User's actions in the Program or on the Site, in particular, the date and time of access to the Program or Site, the history of search queries in the Program or on the Site, information about the addition of any content (if applicable).

    4.2. The Operator assumes that the information provided by the User is accurate and does not verify it. The Operator also assumes that the User has the legal capacity necessary and sufficient to provide Personal Information.

    4.3. The Operator does not process biometric personal data and special categories of personal data of the User.

    5. Terms of collection and processing of Personal information

    5.1. The User agrees and instructs the Operator to perform the following actions: processing, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), comparison, extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion of Personal Information, including in personal data information systems with or without the use of automation tools.

    5.2. Personal information is collected upon registration of the User by filling out the registration form, as well as subsequently when the User edits previously provided information, or when the User supplements previously provided information (if applicable).

    5.3. The Operators also collect Personal Information during the User's use of the Program or Website. In some cases, the collection of Personal Information begins from the moment the User gains access to the Program or Website (e.g., when downloading the Program or Website) until the User registers.

    5.4. Personal information is kept confidential, except in cases where the User voluntarily discloses information about themselves to an unspecified number of persons.

    5.5. The Operator has the right to transfer Personal information to third parties in the event that the User has expressed his consent to such transfer, and (or) the transfer of Personal information is necessary for the User to use certain functions, capabilities of the Program, the Site, and (or) to fulfill the agreement with the User (in particular the user agreement), and (or) in order to ensure the possibility of protecting the rights and legitimate interests of the Operator, or in the event that the need to transfer Personal information is due to the requirements of the legislation of the Russian Federation.

    5.6. The Operator processes Personal Information in accordance with the following principles:

    5.6.1. Legitimacy of the purposes and methods of processing Personal information;

    5.6.2. Conformity of the purposes of processing Personal information with the purposes previously determined and declared during its collection, as well as with the powers of the Operator;

    5.6.3. Conformity of the volume and nature of the processed Personal Information, as well as the methods of its processing, with the purposes of processing Personal Information.

    5.7. Information is processed primarily automatically, without access by the Operator's employees. If access to Personal Information is required for the Operator's employees, such access is granted only to the extent necessary to perform their duties. The Operator's employees are also responsible for complying with Personal Information protection requirements. To protect and ensure the confidentiality of Personal Information, the Operator's employees are required to comply with technical and organizational security measures that comply with the requirements of Russian Federation law.

    5.8. The processing of Personal Information may be entrusted to third parties to achieve the purposes of processing Personal Information. The list of third parties authorized by the Operator to process Personal Information is determined by the Operator independently. The User gives full and unconditional consent to the transfer of Personal Information by the Operator to third parties, as well as to the processing of Personal Information by such third parties.

    5.9. The Operator shall take the necessary organizational and technical measures to protect Personal Information from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other illegal actions in relation to Personal Information, in particular:

    5.9.1. Adoption of local regulations and other documents in the field of processing and protection of personal data;

    5.9.2. Application of legal, organizational and technical measures to ensure the security of personal data in accordance with the provisions of the legislation of the Russian Federation in the field of personal data;

    5.9.3. Implementation of internal control over the measures taken to ensure the security of Personal Information;

    5.9.4. Familiarization of the Operator’s employees directly involved in the processing of Personal Information with the provisions of the legislation of the Russian Federation on personal data and local acts on issues of processing Personal Information;

    5.9.5. Other measures provided for by the legislation of the Russian Federation in the field of personal data.

    5.10. Once the purposes of processing Personal Information have been achieved, the Operator shall cease processing the data.

    6. Use of Cookies

    6.1. When using the Program and the Website, the following types of Cookies may be used:

    6.1.1. Strictly necessary cookies: these cookies are necessary for the operation of the Program and the Website and for providing the User with the functionality of the Program and the Website; among other things, they allow the Operator to identify the User’s hardware and software;

    6.1.2. Statistical (analytical) cookies: these cookies allow us to recognize the User, collect information about the actions performed by the User in the Program or on the Site, and count the number of users;

    6.1.3. Technical Cookies: these Cookies collect information about how the User interacts with the Program and the Site, which allows us to identify errors and test new functions of the Program and the Site to improve the performance of the Program and the Site;

    6.1.4. Functionality Cookies: These Cookies enable the provision of certain functions to facilitate the use of the Program and the Website, for example, by storing preferences (such as language and location);

    6.1.5. Tracking Cookies (Advertising Cookies): These cookies collect information about traffic sources, pages visited, and advertisements displayed to the User. They allow the display of advertisements that may be of interest to the User based on an analysis of the information collected about the User. They are also used for statistical and research purposes.

    6.2. Cookies may be processed by the Operator for the purposes, under the terms and in the manner specified in this Policy, in particular for the purpose of developing the most useful functionality of the Program and the Website, correcting errors in the operation of the Program and the Website, and for conducting statistical research.

    7. Storage of Personal Information

    7.1. Personal information is stored on the territory of the Russian Federation for as long as necessary to achieve the purpose for which it was collected.

    8. User Rights

    8.1. The user has the right to:

    8.1.1. Access information about yourself by viewing your Profile;

    8.1.2. Change (or) supplement information about yourself, which is reflected in the Profile;

    8.1.3. Revoke consent to the processing of Personal Information;

    8.1.4. Request deletion of Personal Information;

    8.1.5. Exercise other rights provided for by the legislation of the Russian Federation.

    9. Limitation of liability

    9.1. The Operator shall not be liable for the disclosure and distribution of Personal Information if third party access to such information is conditioned by the privacy level settings of the software installed on the User's devices, or in the event of the User's failure to fulfill or improper fulfillment of the obligation to ensure the confidentiality of his/her login and/or password, or other data that is necessary for the User's authorization in the Program or on the Website.

    9.2. The Operator shall not be responsible or liable for the content of third-party Internet resources linked to in the Program or on the Site, or for the activities and privacy policies of third parties.

    10. Changes and additions to the Policy

    10.1. The Operator reserves the right to unilaterally amend or supplement the terms of this Policy by publishing the amended text (new version) of the Policy on the Website. The new version of the Policy shall take effect on the day following its posting on the Website, unless a different procedure for entry into force is specified in the new version of the Policy.

    10.2. The User undertakes to regularly review new versions of the Policy.

    10.3. The User has the right to refuse to accept changes and additions to this Policy, which means the User’s refusal to use the Program and the Site.

    10.4. Continued use of the Program and/or the Site after changes and/or additions to the Policy constitutes the User’s acceptance and consent to such changes and additions.

    11 Applicable Law

    11.1. This Policy is governed by and interpreted in accordance with the laws of the Russian Federation. Issues not regulated by this Policy shall be resolved in accordance with the laws of the Russian Federation.

    Equipment compliant with the certificate: